Ready-Made Connecting devices (cables) under EMC directive?

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During the revision of the EMC directive 89/336/EEC, back in 2003, one of the most controversial proposals was the inclusion of “Ready-made connecting devices” within the scope of the EMC directive.

Ready-made connecting devices would encompass passive product, typically 3rd party in nature, designed to interconnect and be connected to apparatus covered within the scope of the directive, in effect classifying such connecting devices as apparatus themselves within the scope of the directive.

Products such as network cables, Audio / Video cables, and other interconnecting cables and adaptors would come under such classification and be subject to the protection requirements of the EMC directive (to paraphrase; must not interfere with others and must operate in the presence of interference without significant loss of performance) , thus requiring testing and marking as any other apparatus would.

It was argued that the term, “Ready-made connecting devices”, itself was ambiguous and unclear. Eventually it was decided that the devices represented no major interference potential, and because of the costs manufactures would incur for testing and marking, it was removed from the scope of the directive.

With the current revision and alignment of the EMC Directive with New Legislative Framework (NLF), the EMC directive 204/108/EC once again is subject to modification, and potential scope expansion. One such change being circulated for inclusion is that ready-made connecting devices be considered again and brought under the regime of the EMC directive.

In a proposal from the German Administration (BNetza), it is argued that in light of experience gained since 2003, the non interference claims argument cannot be maintained. The proposal claims there is no longer any serious doubt that insufficiently shielded connecting devices greatly increase the interference potential of TV and Cable networks in particular. The proposal cites several reports with data supporting this conclusion. One such report shows a  peak 30dB difference in screening effectiveness between two types tested, from most to least shielding, and notes that cable connectors can contribute around 10 dB of difference. See   ”The Concise Report of the CENELEC/ETSI Joint Working Group on the digital dividend" of 12 August 2010 (section 7.3)

The proposal suggests  that the following requirement be added to the new EMC directive;

Ready-made connecting devices, although incapable of generating electromagnetic disturbance in isolation, may generate or transmit electromagnetic disturbance when connected to an apparatus and should therefore be considered to be apparatus for the purposes of this Directive.

With ready-made connecting devices being defined as;

ready-made connecting devices' intended for connection to an apparatus by an end user for the transmission of signals, which are placed on the market separately from such apparatus, and which are liable to generate or transmit electromagnetic disturbance when connected to it.

This addition would then subject cables and connectors to the same technical requirements as any other product under the EMC directive, regardless of the component’s active or passive nature.

EN 55013 modified and draft going for vote

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EN 55013 is the EMC emissions standard for broadcast receivers and associated equipment. The standard is aligned with the European Union’s EMC directive as published in the official journal. The EMC directive is a CE marking directive, and compliance with this directive is compulsory for most electrical / electronic products prior to placing on the European market.

Previously reported in a post back in the summer of 2009, EN 55013, QP vs RMS, it was noted that the EU commission was holding off publishing reference to the newest edition of EN 55013, 2009, in the Official Journal.

The CENELEC technical committee, CLC/TC 210, had decided that the standard should not be published, without the link to the EMC Directive, and accordingly has set up a task force to seek a resolution.

It was agreed that the new draft common modifications should be circulated under UAP. The current project name is EN 55013:201X

The CLC/TC 210 Secretary proposed that the following explanation appear in the forward to the draft common modifications, furthermore this is not to be included in the final publish standard, should the draft be accepted:

“The text of CISPR/I/296/FDIS, the future CISPR 13 ed 5.0, received a positive vote in CENELEC, but was not ratified due to technical objections raised by the EMC Consultant. These would have prevented the listing of the standard in the Official Journal of the European Union as a harmonised standard providing a presumption of conformity with the protection requirements of the EMC Directive 2004/108/EC. The following draft includes common modifications to address these objections, and they have been agreed by the EMC Consultant and the responsible committee, TC210. It is submitted to UAP.”

It is expected that in light of the upcoming CISPR 32, perhaps appearing within a couple years, that EN 55013 will then be deleted. At that time, the use of the QP detector will have become obsolete and replaced by the RMS/Average detector.

It should be noted that the UK is not in favor of issuing the document under UAP, nor is Italy. The UK proposes to wait and see what happens with CISPR 32. The draft will be submitted under UAP none the less.

The last word on Power Line telecom (PLT) in the EU, EN 55022:2006 applies in full, maybe….

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Power Line communication devices continue to be a controversial subject, with respect to the Electromagnetic Compatibility of such devices. We have been following this subject for both the United States, and for Europe. The latest round comes from across the pond with the rejection (negative vote) of the European Norm targeted to cover the testing of these devices, prEN 50561-1:201X. For background on this topic, see my past article “An update on PLT, Power Line Telecommunications, in Europe”.

Due to the negative vote on prEN 50561-1:201X, and a lack of a specific standard covering the emissions testing for PLT devices, EN 55022:2006 applies in full for these devices as of October 1st. It should be noted that many newer high speed advanced PLT devices cannot pass the requirements of EN 55022:2006 at this time.

This conclusion will be confirmed by a note published in the Official Journal reference to harmonized standards under the EMC directive.

CENELEC may offer a second vote, indicating that the choice is between EN 50561-1 and EN 55022. If this vote fails, no further option exists.

What does this mean for product on the market? Are recalls required for non compliant devices? What about new product placed on the market? The Commission is expected to accept a reasonable Date of Withdrawal (DoW) as proposed by working group 11, and until that date, manufacturers should still be able to continue placing product on the market using the Declaration of Conformity and Notified Body TCF path. The EU market authorities are “encouraged” to accept this.

The group of European Notified Bodies are meeting to discuss, and will consider the Technical Guidance Note (TGN) on the matter, after the meeting. Is this the end of the debate? Time will only tell, and we’ll continue to post when we learn more.

FCC holds workshop on Switched Telephone Network in transition

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For those of us in the technology field and most tech savvy consumers, as well as 40% age 18-30, an analogue phone connected to a pair of wires, heading off to a central switch, may seem antique and obsolete. The facts are that many still depend on this for communication. However those numbers are dwindling fast, and the time to consider the way forward, according to the FCC, is now.

According to a Mercury news report in 2009, the recession gave a “push” and for the first time during the last half of 2008, American homes with cell phones but no landlines outnumbered those with landlines but no wireless devices, due to consumers being forced to make an economic choice of one over the other. According to an April 2011 CBS news report a new federal study says that more than a quarter of homes in the United States now have only a wireless phone.

FCC regulations govern many aspects of the PSTN (Public Switched Telephone Network) such as equipment interoperability and protection of the network, access for persons with disabilities, hearing aid compatibility and others. The FCC will need to evaluate these issues more intently as the move to alternative forms of  main communication hastens.

The FCC will be holding two workshops to examine the transition from the traditional PSTN to new technologies.

The first workshop will focus on obstacles and opportunities the transition may create regarding public safety, availability and accessibility. This workshop will also evaluate “Non-carrier” stranded assets, such as alarm monitoring systems that would be left behind. This workshop will be held the morning of December 6, 2011.

The second workshop will examine economic, technological and policy issues that need to be addressed as consumers choose new technologies and services. This workshop will be held December 14.

Both workshops will be held in Washington DC as well as streamed live at http://www.fcc.gov/live

The Public notice is available here; http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db1110/DA-11-1882A1.pdf

FCC requests comments on TV bands database test

The OET (Office of Engineering and Technology ) is requesting comments on the Spectrum Bridge Inc. database system trial that was recently completed.

Comments are due by Nov. 28th 2011, and reply comments by Dec. 5th 2011. All comments must be filed using the Commission’s Electronic Comment Filing System.

ECFS: http://fjallfoss.fcc.gov/ecfs2/.

The full press release can be found at http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db1117/DA-11-1872A1.pdf

Hearing aid compatibility for wireless handsets

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FCC publishes Second Further Notice of Proposed Rulemaking covering wireless hearing aid compatibility rules for handsets. Interested parties may file comments and reply comments on or before December 1st and December 16th respectively.

FCC seeks comments on conclusion to adopt the new 2011 ANSI standard into the Commission’s rules as applicable technical standard for evaluating hearing aid compatibility of wireless phones. The proposal is to adopt the new standard as “permissible” rather than mandatory, with the intent to ease burdens on manufacturers.

Within the discussion of the proposed rulemaking document, the FCC “tentatively concludes that the adoption of the new technical standard would not raise any major compliance issues or impose materially greater obligations with respect to newly covered frequency bands and air interfaces than those already imposed under Commission rules”.

Under the proposed rules, a manufacturer will be permitted to submit for certification using either the 2007 version, or the 2011 version of the ANSI standard.

Broadband over Power line systems rule amendment

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FCC Part 15 has been amended with new rules covering BPL systems. In July of 2009, a request for further comment was issued (See previous post), this is the conclusion of the commission’s response to the directives of the DC Circuit Court of Appeals remand,  after a challenge by the National Association for Amateur Radio, AKA American Radio Relay League (ARRL).

In this rule change, the commission finds that the information submitted in response to the RFC/FNPRM does not warrant any changes to the emissions standards or the extrapolation factor.  The rules do include some notable changes, among them, modification of the rules to increase the required notch filtering capability for systems operating below 30 MHz from 20 dB to 25 dB, and, establishing a new alternative procedure for determining site-specific extrapolation factors generally as described in the RFC/FNPRM, furthermore, adopting a definition for the “slant-range distance” used in the BPL measurement guidelines to further clarify its application.

Read the full ET Docket No. 03-104, Second Report and Order.

FCC issues a number of updates

A total of 6 guidance documents and 3 drafts for review were posted today on the FCC site, among these updates are procedures for Multi antenna systems (i.e. MIMO) as well as U-NII devices . This list includes the following updates;

Publication Number	Question	Answer
628591	What equipment cannot be certified by a Telecommunications Certification Body?	The attached document 628591 D01 TCB Exclusion List v12r01 identifies equipment that are excluded from being certified by a TCB.
610077	What are the post market surveillance requirements for a Telecommunications Certification Body (TCB)?	Section 2.962(g) of the FCC Rules requires a TCB conduct appropriate post-market surveillance activities in accordance with ISO/IEC Guide 65. The requirements for TCBs were specified in the Commission's Report and Order (R&O) in GEN Docket 98-68 (FCC 98-3...
648474	What are the test procedures for SAR evaluation for handsets that contain multiple transmitters and antennas or wireless charging battery covers?	The attached documents: 648474 D01 SAR Handsets Multi Xmiter and Ant v01r05 provides SAR evaluation considerations for handsets with multiple transmitters and antennas. 648474 D02 SAR Policy Handsets Multi Xmiter Ant v01r01 provides policies for SAR Evaluation….
662911	How are measurements made on a device that employs a single transmitter with multiple outputs in the same band?	The attached document, 662911 D01 Multiple Transmitter Output v01r01 provides guidance for measurements of conducted output emissions of devices that employ a single transmitter with multiple outputs in the same band. The guidance applies to devices that ...
789033	What are the general test procedures for measuring compliance of U-NII devices to Section 15.407 requirements?	The Attachment below - 789033 D01 UNII General Test Procedures v01- provides test procedure guidance for measuring compliance to the general technical requirements of Section 15.407. Note: This test procedure replaces and supersedes guidance contain...
690783	What are guidelines for TCBs for listing SAR numbers on FCC equipment authorization grants?	The attached document -690783 D01 SAR Listings on Grants v01 -provides guidance for Telecommunication Certification Bodies (TCBs) for uniform listings of specific absorption rate (SAR) numbers in the comments field of grants of certification.

In addition, a number of drafts are available for review and comment;

Date Posted:
Oct 25 2011 4:13PM
Last Date to Post Comments:
11/25/2011
View Document:
Comments, Notes, and Conditions Listed on OET Equipment Authorization Certification Grants

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Date Posted:
Oct 25 2011 9:25AM
Last Date to Post Comments:
11/25/2011
View Document:
Confidentiality

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Date Posted:
Oct 25 2011 9:10AM
Last Date to Post Comments:
11/25/2011
View Document:
Permit But Ask procedure & Permit But Ask List

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Date Posted:
Oct 3 2011 9:52AM
Last Date to Post Comments:
11/04/2011
View Document:
Guidance for Performing Compliance Measurements on Digital Transmission Systems (DTS) Operating Under 15.247
There have been 3 comments made on this document:

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Updated list of standards published in the Official Journal of the European Union, under the R&TTE directive, on 9/21/11.

Find a copy on Compatible Electronics', European Conformity Assessment page, or at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2011:277:0001:0035:EN:PDF

By: J Klinger

Q&A; applicability of EMC directive to SIM (subscriber identity module)

Question:

Application of the EMC Directive to SIM.

“Does the EMC Directive apply to smart cards, SIM cards and other contact cards? If so, what do you think are the applicable standards?”

Answer:

My understanding is that the common SIM requires an external power source and data interface to function, so assuming the SIM card performs no independent intrinsic function, and thus is not considered an "apparatus", but rather a "component" or "Sub-assembly" and must be paired with a device designed to operate with it, the EMC directive is not independently directly applicable to the SIM.

However, the SIM will be subjected to the same environment the intended host is subjected to, so it should be capable of compliance under such conditions, and with whatever directive(s) the host, or hosts, are governed by, and should not compromise the compliance of any given host. However, testing in one configuration considered "Typical" does not automatically guarantee compliance in all use cases.

Testing to a given set of harmonized standards is one of the tools used to assess compliance with the essential requirements of a given directive, but is not a requirement in and of itself, nor does it guarantee compliance with the essential requirements.

The broader the use case, the broader the assessment needs to be. Consider mobile phones, medical devices, information technology equipment, etc...

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Note the “Answer” to the question presented is only opinion, but based on extensive knowledge of the applicable EMC requirements. The responsibility for compliance with any requirement rests with the given product manufacturer.

FCC’s first wave crackdown against signal jammers

The Federal Communication Commission is making good on its warning to signal jammer vendors on Friday Sept. 30, issuing a sweeping citation to 20 of them.

Earlier this year, the FCC issued a warning to consumers and vendors of the illegal nature of jamming devices, and warned would-be violators of the consequences that may come if selling or using such devices.

The vendors listed in the citation order are all online vendors that offer a range of illegal jammers such as GPS blockers for vehicles, high-tech signal blockers with remote control capabilities, jammers disguised as paintings and cigarette packs, other small, easily-concealable cell phone jammers, as well as high powered industrial jammers that have the potential to disrupt radio signals in areas as large as a football field.

The citation requires that the online vendors report within 30 days on their specific actions taken to correct the violation. The citation also warns that continued violation may bring fines, equipment seizure or imprisonment.

By: J Klinger

EMC list of harmonized standards update, new ITE standards

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The list of standards for use under the EMC directive, 2004/108/EC, published in the Official Journal of the European Union has been updated.

Among the updates within the list are the inclusions of the 6th edition of the emissions, and 2nd edition of the immunity standards, for Information Technology Equipment (ITE), titled EN55022:2010 and EN55024:2010. These official titles are the modified version of CISPR 22:2008, and unmodified CISPR 24:2010.

The inclusion in the official journal is a prerequisite for a standard to be considered harmonized for use in the presumption of conformity with the essential requirements of a given directive. This allows these new standards to be used for compliance testing.

These new versions will supersede their predecessors on December 1st 2013, at which time they become mandatory. Any new product shipped into the European Union on or after December 1, 2013, must comply with the new ITE specifications.

You can find a copy of this list at Compatible Electronics’ European Conformity Assessment page, or at the the EC Enterprise and Industry web site when available.

 

By: J Klinger

European Harmonized standards list update

The list of harmonized standards for the following directives have been updated.

updated 8/19/11. Council Directive 93/42/EEC of 14 June 1993 concerning medical devices. Other language copies can be found here

Updated 8/31/11Directive 2006/95/EC of the European Parliament and of the Council of 12 December 2006 on the harmonisation of the laws of Member States relating to Electrical Equipment designed for use within certain voltage limits. Other language copies can be found here

As always copies of the newest lists for EMC, R&TTE, LVD and Medical Devices can also be found at http://celectronics.com/europe.htm

By: J Klinger

Omission of Class B statement in users manual costs…

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The Federal Communications Commission( FCC) issued a Notice of Apparent Liability for Forfeiture (NAL) to Marshall Amplification PLC, seeking $7500 for what the FCC claims is “willful and repeated” violation of section 302(b) of the Communications Act and sections 2.803(a)(2) and 15.105(b) of the
Commission’s rules.

The notice follows a complaint received by the FCC that Marshall had not included the proper consumer disclosure in the users manual of some Class B digital devices being sold by Marshall. It is noted in the NAL that the products were verified for compliance with the Class B limits and the technical requirements had been met, thus the base forfeiture amount was adjusted down as a result, however, the forfeiture amount was adjusted  back up based on Marshall’s ability to pay, stating “large or highly profitable entities, such as Marshall should expect forfeitures higher than those reflected in the base amounts”

In general most consumers are unfamiliar with the requirements and rules of the FCC, and it can be assumed that a large amount of complaints received by the FCC are filed by industry competitors, excluding those cases that deal with actual radio interference.

The consumer disclosure in question is intended to inform the user of the potential for interference and what to do should it occur, and is required for all class B digital devices.

“ This equipment has been tested and found to comply with the limits for a Class B digital device, pursuant to part 15 of the FCC Rules.  These limits are designed to provide reasonable protection against harmful interference in a residential installation.  This equipment generates, uses and can radiate radio frequency energy and, if not installed and used in accordance with the instructions, may cause harmful interference to radio communications.  However, there is no guarantee that interference will not occur in a particular installation.  If this equipment does cause harmful interference to radio or television reception, which can be determined by turning the equipment off and on, the user is encouraged to try to correct the interference by one or more of the following measures:

• Reorient or relocate the receiving antenna.
• Increase the separation between the equipment and receiver.
• Connect the equipment into an outlet on a circuit different from that to which the receiver is connected.
• Consult the dealer or an experienced radio/TV technician for help. “

A NAL is not a forfeiture order, it usually follows a Letter of Inquiry, and the recipient of one can still seek dismissal and/or reduction in the amount. The process ends in one of three ways, an actual forfeiture order, a consent decree, or criminal prosecution, with the latter being rare.

While, with regard to this particular incident, the cost of this omission may be $7500, and some may consider this as simply the cost of doing business, it should be noted that the fines can be much higher for willful and repeated violations, and could be cumulative based on each product sold and compounded for each day the violation occurs.

The complete NAL can be found at http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0830/DA-11-1468A1.pdf

EMC Society’s John Howard Memorial University Grant

The call for proposals to the IEEE EMC Society’s University grant program has been announced.

The program is designed to assist in adding EMC fundamentals to the curriculum of a qualified University or College. The award is $5000, intended as seed money for the establishment of the program.

Details can be found at http://www.emcs.org/committees/education/univ_grant/index.html

The Call for Proposals can be found at http://www.emcs.org/committees/education/univ_grant/UGC_Call_2011.pdf

By: J Klinger

Draft FCC publication for SAR listing on grants

New guidelines have been published by the FCC for the uniform listing of Specific Absorption Rate (SAR) numbers on the grant of equipment authorization.

This is of primary interest to Telecommunication Certification Bodies (TCBs), those being responsible for the actual grant of equipment authorization.

Last date to post comment: 9/16/2011, post comment at https://apps.fcc.gov/eas/comments/PostComment.do?id=197&tn=359396

See “SAR Listings on Equipment Authorization Grants”

By: J Klinger

FCC publishes new draft testing guidelines for U-NII devices

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Public comment is now open, until September 23, 2011, on the FCC guidelines for testing Unlicensed National Information Infrastructure (U-NII) devices, in accordance with CFR 47 Part 15, Subpart E.

In addition to the measurement standards called out in section 15.31, and ANSI C63.10, these guidelines will form the general test procedures for testing all U-NII devices for compliance with the technical requirements of section 15.407.

The U-NII radio band is an unlicensed band divided into three spectrum segments in the 5GHz range, 5.15–5.35 GHz, 5.47–5.725 GHz and 5.725–5.825 GHz. U-NII devices use wideband digital modulation techniques, and provide a wide array of high data rate mobile and fixed communications for individuals, businesses, and institutions. Examples are 802.11a devices.

Dynamic Frequency Selection (DFS) functions, which are required between 5.25 – 5.35 GHz and between 5.47 – 5.725 GHz for the protection of government radar systems, are covered in a separate document. See FCC Order, ET Docket No.03-122 (FCC 06-96).

For devices that transmit on multiple outputs simultaneously such as MIMO and beam forming technologies, FCC KDB Publication Number 662911 also applies.

The new guidance replaces Public Notice DA 02-2138 of 8/30/02 and contains the following changes;

• The document interprets and clarifies the language of 15.407(a)(4) (maximum conducted output power)
• Revises the spectrum analyzer-based methodologies for measuring maximum conducted power and provides an option to use an RF power meter
• Revises the methodologies for measuring Peak Power Spectral Density (PPSD) to match those used to measure maximum conducted output power
• Specifies the use of max hold when measuring Emission Bandwidth (EBW)
• Defines compliance with 15.407(a)(6) (peak excursion) in terms of the ratio of maximum of the peak-hold spectrum to the maximum of the average spectrum—eliminating the need to compute the ratio at each frequency (a process that had resulted in unintended failures near band edges)
• Adds guidance for measuring unwanted emissions.  The guidance interprets the non-restricted band limit as a peak limit and restricted band limits as including both average and peak limits.  Both restricted and non-restricted band limits are based on continuous transmission with no subsequent reduction for operational duty cycle.  The guidelines permit both restricted and non-restricted band compliance be demonstrated by radiated measurements or by antenna-port conducted measurements combined with radiated cabinet emission measurements.

By: J Klinger

IEEE EMC Society 2011

The 2011 IEEE EMC society symposium is underway in Long Beach, California. Be sure to drop by Compatible Electronics' booth #531.


By: J Klinger

$22,000 for operating an unlicensed radio station

A Florida resident has been issued a monetary forfeiture order for $22,000 by the FCC, for operating an unlicensed radio station out of her home and refusing to allow it’s inspection by field officers.
Read the monetary forfeiture at http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1266A1.pdf

Spectrum Sharing agreements with Canada and Mexico, announced by the FCC

The FCC reached agreements with Canada and Mexico for sharing commercial wireless broadband spectrum in the 700MHz band along the respective boarders, additionally, an arrangement has been made with Canada for sharing spectrum in the 800MHz band.

The goal of these arrangements is to further the deployment of commercial wireless broadband services near the boarder, with an aim to providing consumers additional options for 4G high speed mobile broadband access in these areas.

The arrangements made with respect to the 800MHz band on the northern boarder are inline with the 800MHz rebanding efforts by U.S. public safety and ESMR (Enhanced Specialized Mobile Radio) i.e. Nextel. Specifically the allotment of channels between the US and Canada, technical operational parameters within 87 miles of the boarder, and setting the schedule for transitioning facilities from US channels to complete the rebanding along the U.S.-Canadian border.

Read the FCC Press release at http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0801/DOC-308822A1.pdf

By: J Klinger

Microsoft is designated a TV bands database admin, follows Google

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Microsoft Corporation received conditional designation by the FCC as a TV bands database administrator. Microsoft joins Google and 8 others, Comsearch, Frequency Finder Inc., KB Enterprises LLC and LS Telcom, Key Bridge Global LLC, Neustar Inc., Spectrum Bridge Inc., Telcordia Technologies, and WSdb LLC. This brings the list of available administrators to 10 in total. 

The TV bands, or television “white spaces” are the unused portions of the broadcast television spectrum, freed by the transition to digital TV. Availability within the spectrum varies with geographical location; the TV bands database is used as a control and coordination measure for the bands. It is required that devices that would use this unlicensed spectrum would include a geo-location capability and access to the database, containing frequencies off limits for use in that area, enabling devices to communicate without interfering with incumbent users. 

Manufacturers of devices are free to choose which database to use in their devices. Database administrators may charge fees for access to the database. In lieu of geo-location and database access, devices can employ hardware that listens to the band, called spectrum sensing, this requires approval by the FCC first, each application must be placed on public notice, and the FCC will conduct tests to evaluate performance prior to approval, which could result in a far more costly product. 

Each approved database administrator must make their database available for a 5 year term. At this time all administrators are conditional and pending, the FCC will announce when and if any particular administrator is available for public use.

By: J Klinger

Power Line Communication Limits and methods of measurement draft Part 1

Draft standard EN 50561-1 Power line communication apparatus used in low voltage installations up for public inquiry. The following links point to further information on this upcoming test specification.

http://standardsdevelopment.bsigroup.com/Home/Project/201100247

http://iaru-r1.org/pipermail/wg_iaru-r1.org/attachments/20110204/9a94f73f/attachment-0007.doc

http://www.cenelec.eu/dyn/www/f?p=104:110:1624662092856985::::FSP_PROJECT,FSP_LANG_ID:23145,25

---Correction 7/21/11

This draft European Standard is submitted to CENELEC members for formal vote, not public inquiry. Deadline for voting: 2011-08-26.

The standard has a  +6 month date of announcement, a +12 month date of publication, and a +36 month date of withdrawal . The +36 month dow  is subject to change during voting.

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By: J Klinger

Radio interference from LED lighting

Image via https://commons.wikimedia.org/wiki/File:2007-07-24_High-power_light_emitting_diodes_(Luxeon,_Lumiled).jpg

Interference reports suspecting LED lighting products, emitting electromagnetic energy, causing problems with VHF radios and other receivers are nothing new, just do a Google search and you’ll find complaints of such problems. These complaints are few and scattered, possibly due to the lack of mainstream adoption of LED lighting, but that is all about to change.

Many regions have, or are adopting, rules aimed at reducing waste from lighting products, from toxic substances such as mercury, as well as overall power consumption reduction of lighting products. A growing trend around the globe is the general phase-out of incandescent bulbs.

While CFLs (Compact Fluorescent Lamps) are far more efficient in terms of power consumption than traditional incandescent lighting, like all fluorescent lights, they contain mercury, a toxic substance, thus complicating disposal and presenting an environmental hazard.

An alternative to CFL is LED lighting, or Light Emitting Diode. Newer LED technology has the benefit of much lower power consumption compared to traditional lighting, as well as the reduced environmental impact, and, compared to several years ago; they are becoming increasingly more affordable. It has been stated that more than 50% of our electricity consumption for lighting would be saved if the efficacy reached 200 lm/W (lumen per Watt). LED efficacy reached 100 lm/W in 2010, and continuing the trend, they will easily hit the 200 lm/W mark by 2020 as predicted. Some companies claim that they have already attained this level of efficacy.

However, although today’s LEDs are capable of long life, and delivering high light output levels with very little power consumption, most need to be paired with a drive circuit to provide constant current sourcing to operate in our homes and offices, and that’s where the problem comes in. These switching drive circuits operate at increasingly higher frequencies, and in order to maintain the highest efficiency, and highest LED longevity possible, they also need to maintain very high slew rates. These factors contribute to the overall unwanted emissions from each individual lighting element, increasing the Electromagnetic background noise.

Electromagnetic Interference or EMI mitigation inevitably increases the overall cost of products by adding additional components to a design, or requiring a more complicated and expensive design and layout, and for low price consumer electronics, with very small profit margins, every penny counts. As EMI mitigation is considered by some as an unnecessary expense, it is often overlooked or simply disregarded. Proper operation and safety concerns also make engineering a quiet design more difficult and expensive. So the cheaper LED lighting will potentially be the most problematic in terms of interference, but they will also be the preferred choice for the average consumer, and therefore the most prevalent.

Couple the added costs with the lack of regulatory enforcement and oversight governing the EMI of these devices and you can see the potential problem this poses. Most of the interference may be caused by very high frequency emissions, typically in the 30 – 300 MHz range, and possibly higher.

In the US, most products capable of causing interference that may be used in the home and office fall under FCC Part 15 rules governing the amount of unwanted electromagnetic energy that products can produce, both conducted on the power lines, and radiated from the products themselves, to prevent interference to radio receivers and for the overall protection of the radio spectrum. For most products, compliance with these rules however is primarily based on the honor system, and requires that manufacturers be knowledgeable in the application of the rules and proper test methods. Common misinterpretation of the rules, may lead manufacturers of LED lighting to address only the lower frequency conducted disturbance, or possibly to consider themselves exempt from the rules altogether. This may only be addressed by the FCC when problem reports become widespread.

Europe has addressed, and continues to monitor, some of these issues, with the amendment of standards covering lighting product emissions, such as EN 55015:2006, adding emission measurement requirements from 30-300MHz. Confusion may still exist on the proper application of the harmonized standards, possibly leading to improper evaluation of electromagnetic emissions, and it’s questionable if the frequency range is high enough to cover some products found on the market today.

In New Zealand, a report issued in the summer of 2010 warns of the potential interference that LED lighting products could pose, and urges reports of any interference problems to the Radio Spectrum Management.
As LED lighting products enjoy mass adoption, it is possible that mysterious failures of everyday things we have come to depend upon such as remote controllers, baby monitors, radio receivers, garage door openers, security systems, just to name a few, may be just around the corner. This doesn’t need to be the case however, as the problems are preventable with careful consideration and a desire to do so.


By: J Klinger

Do you mind turning off your RF device please?

Image by James Provost via Flickr

According to a Parliamentary Assembly of the Council of Europe (PACE) report issued May 6, 2011, “waiting for high level scientific and clinical proof that electromagnetic fields emanating from high frequency sources such as radar, telecommunications and mobile phones may lead to very high health and economic costs”.
PACE will be meeting in Kyiv on May 27th, and hold a debate, and intends to adopt a resolution on the issues raised in the report.
The report invokes heath concerns, in particular using examples of asbestos, lead, and tobacco, as mistakes made in the past when dealing with unknown health risks. The report also likens the potential consequences on the environment by electromagnetic fields with licensing of medication, chemicals, pesticides, heavy metals and genetically modified organisms.
The report recommends that an “as low as reasonably achievable” approach be adopted when setting standards or threshold values for emissions of electromagnetic fields of all types and frequencies. The report urges that particular attention should be given to protecting children, and “electrosensitive” persons suffering from a syndrome of intolerance to EM fields with a call to protect them from the unknown effects of electromagnetic waves by the creation of “Wave-free” areas not covered by wireless networks.
Mobile phones, DECT phones, WiFi, WLAN and WIMAX come under focus in the reports, with the call for microwave long-term exposure thresholds of not to exceed 0.6 v/m and in the medium term reduced to 0.2 v/m. The report also makes recommendations to; undertake risk-assessments prior to licensing new types of devices, calls for additional labeling and indications of health risks, produce warnings and recommendations to use a wired alternative due to the “unknown” dangers of electromagnetic fields..
The report proposes the ban of all mobile phones and wireless networking devices from schools and classrooms.

By: J Klinger

US Mexico MRA

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A new US-Mexico Telecom MRA was signed May 26th 2011, indicated in a press release from the United States Trade Representative.

The agreement is for the recognition of testing laboratories and acceptance of test reports. Mexico will only recognize 3rd party labs. The agreement does not cover recognition of certification bodies. The agreement includes a transition period. Seven accepted  technical regulations (NOMS) are listed in Annex I of the MRA text.

The FCC OET is conducting 1st workshop for TV band database administrators

 

The Federal Communication Commission’s Office of Engineering and Technology is conducting the first mandatory workshop for TV band database administrators. The workshop will be held on March 10^th, 2011, at the FCC lab in Columbia, Maryland.

Nine entities are on the list of conditionally designated administrators - Comsearch, Frequency Finder Inc., Google Inc., KB Enterprises LLC and LS Telcom, Key Bridge Global LLC, Neustar Inc., Spectrum Bridge Inc., Telcordia Technologies, and WSdb LLC. While all nine entities are required to attend, the workshop is open to other interested parties, the number of attendees will be limited however, and all parties attending must register in advance.

The workshop topics include 1) the construction of the database(s), including its contents, 2) sharing of information among the databases, and 3) the determination of available channels. In addition, information will be provided on the required security provisions and the database trial periods.

TV Bands Devices are unlicensed devices that will operate in the space between TV channels, at locations where channels are not being used for authorized services, or as is commonly referred to as the White space.

The Laboratory Division of the OET released an Initial evaluation of prototype TV bands “White Space Devices” in 2007, following up with a Phase II evaluation in 2008. The FCC first adopted rules for the unlicensed use of “White Space” devices in November of 2008, under a document titled FCC-08-260A1, Second Report and Order and Memorandum Opinion and Order, in particular this addressed unlicensed operation in the TV broadcast bands and additional spectrum for unlicensed devices below 900 MHz and in the 3 GHz band, these rules were amended by a Second Memorandum Opinion and Order, FCC-10-174A1, in September of 2010.

The rules require that all fixed and Mode II (portable devices with Geo Location capabilities built in) TV bands devices access a database to obtain information on the available channels at their location and require that all unlicensed fixed TV bands devices register their operations in this database. The databases will be privately owned and operated, currently by the nine entities listed above. Which database the device will use will be determined by the user or manufacturer of the particular device(s)

For updates to current FCC rules and requirements, please visit Compatible Electronics, Inc. on the web at http://CElectronics.com, or subscribe to the feed.

References

· DA-11-404A1 · DA-07-3457A1 · FCC-08-260A1 · FCC-10-174A1

· http://www.federalregister.gov/articles/2010/12/06/2010-30184/unlicensed-operation-in-the-tv-broadcast-bands

FCC reminds the public that radio jammers are illegal to operate in the United States, and warns would-be violators of the consequences of selling or using them

Image by G0SUB via Flickr

In a News Release titled “FCC ENFORCEMENT BUREAU STEPS UP EDUCATION AND ENFORCEMENT EFFORTS AGAINST CELLPHONE AND GPS JAMMING.”  The FCC warns and reminds consumers that it is a violation of federal law to use a cell jammer or similar device that would intentionally block, jam, or interfere with authorized radio communications.

In a kind of public outreach, the news release by the FCC Enforcement Bureau explains what can happen if you use a cell jammer, why jammers are prohibited, and information on how to file a complaint alerting the FCC to illegal jamming device usage. A copy can be downloaded at http://www.fcc.gov/Daily_Releases/Daily_Business/2011/db0209/DOC-304575A2.pdf.

Additionally, the FCC Enforcement Bureau released a public notice in the form  of an FCC Enforcement advisory. The public notice warns of the strict penalties for marketing or selling jamming devices. Among the penalties, a fine of up to $112,500 can be issued for a single violation. A complete list of jammer enforcement activity can be found at http://www.fcc.gov/eb/jammerenforcement/ A copy of the FCC Public Notice can be downloaded at http://www.fcc.gov/Daily_Releases/Daily_Business/2011/db0209/DA-11-249A1.pdf

Compatible Electronics, Inc. operates a fully certified telecommunication certification body for radio device approvals in accordance with FCC rules, please visit our site at http://www.celectronics.com/us.htm or contact us with your questions about the wireless device approvals process and regulations.

By: J Klinger

IEEE EMC Society Standards Development Committee Withdraws as Cosponsor of IEEE BPL EMC Standard

http://www.arrl.org/news/ieee-emc-society-standards-development-committee-withdraws-as-cosponsor-of-ieee-bpl-emc-standard