Product Safety Engineering

How many years has PSE been involved in the Compliance Industry?

PSE began as a safety laboratory in 1986, working with ITE manufacturers to list their products with UL and CSA.  PSE quickly expanded operations to include an EMC/EMI/TELECOM test facility so that we may deliver a total international compliance package.  

Every key player on our engineering staff has an extensive and expert background in their respective field.  Unlike most oversized agency labs, the PSE EMC facility has seen NO turnover on the engineering staff in over ten years.  This means that you can enjoy the familiarity and knowledge base that grows with each and every project.  Our Open Area Test Site (OATS)  currently performs testing to meet the requirements for US (FCC), Europe (CE Marking), Japan (VCCI), Australia/New Zealand and numerous other Worldwide markets.

Where is PSE's mailing address? Where should I send product / information?

Product Safety Engineering
12955 Bellamy Brothers Blvd
Dade City, FL 33525

Phone (352) 588-2209
Fax (352) 588-2544

Who should I contact at PSE to obtain a quotation?

Contact a PSE Marketing Representative via phone, fax, or e-mail and we will supply a quotation including schedule and time frame for the product evaluation. From that point on, your PSE Marketing Representative will act as your single-point-of-contact for all future inquires. 

PSE Sales Dept.

Andrew Robbins

(352) 588-2209 Ext. 106

(352) 588-2544 Fax

arobbins@pseinc.com

What is FCC Part 15?

Part 15 is a federal regulation that sets exact limitations on the amount of electromagnetic interference (EMI) allowable from digital computing and other electronic devices as diverse as wristwatches and musical instruments, typewriters and telephones. It was promulgated by the Federal Communications Commission under its authority to regulate the airwaves, especially to limit interference with broadcasting.

All electronic devices (unintentional radiators) that contain clocks/oscillators which operate at a frequency above 9kHz must be tested under FCC part 15 Subpart B, radio frequency rules & regulations. The FCC has broken down Part 15 into two categories, Class A (commercial) and Class B (residential).

The FCC's penalties for non-compliant products include halting all distribution, levy of fines and publication of public notices.

What about the new FCC Part 15 Self Declaration Procedures?

Under the new procedures for DoC/Self Declaration there is no longer a need to submit/certify computing devices and peripherals with the FCC.

The manufacture simply has the testing performed at a A2LA approved OATS, applies the new FCC label to there product, and issues a Declaration of Conformity to be shipped with the product. The real benefit is that there is longer a submittal to the FCC, so a product can hit the market as soon as it is shown to be in compliance, saving several weeks in the overall process.

Can I display a product at a Trade Show that is not in compliance with the FCC's Code of Federal Regulations? (e.g. Part 15 & Part 68).

Yes. You can display a product, in the U.S., that hasn't yet meet the FCC requirements provide you post a statement informing the consumer of the product's non-compliant status.  The verbiage of the statement, as defined in the Part 15 rules, can be obtained by request through the PSE Marketing Dept.

arobbins@pseinc.com

Differences in emissions limits?

I have heard that the emissions requirements for Europe, Japan, the US and several other countries are all very similar.  Is it possible to perform one test that covers several markets for emissions?

Depending on the type of product that you manufacture, it may be possible to perform one emissions test, generally based on the CISPR 22 limits, and only perform deviations for the other markets.

However, it is important to confirm that your test lab is qualified and accredited to perform testing for these different markets. For example, the VCCI (Japan) requires that the testing laboratory be a member, and if you are going to self declare a computing device to meet FCC Part 15 requirements, the lab must be A2LA accredited. PSE holds both of these accreditations.

Keep in mind that whether you are trying to meet EMC or safety standards, it is always important to define all intended markets before testing begins. PSE always strives to meet our client's needs in the most cost effective and time efficient course possible. By having a clear understanding of which markets you are seeking, we will be in a better position to satisfy your needs.

What does the FCC mean by Class A or Class B?

Class A

A device which is marketed for use in an industrial application and is not intended for use in the home or residential area. Since the product is being sold to a commercial market, the emissions limits are significantly less stringent than Class B (residential) devices. Products that fall under the category of Class A do not require an official submittal, but simply need a Verification test performed and the data must be keep on hand by the manufacturer.

Class B

A device that is marketed for use in the home or a residential area by the customer. Class B devices can require either Verification, Certification, or Self Declaration depending on the type of product. Class B Verification is for devices that are marketed for in home use, but are not permanently connected to a personal computer. Computing devices and peripherals need to meet the same test limits, but the formal data needs to be submitted to the FCC for Certification, or the manufacturer can choose to issue a Declaration of Conformity under the new FCC DoC/Self Declaration Procedures.

What if my product experiences a failure during the formal testing? Can PSE provide engineering / diagnostic support?

Yes, PSE employs a staff of experienced engineers whose chief responsibility is providing engineering assistance to bring our client's product into compliance. Whether you are looking for pre-compliance design review, a quick retro fit, or complex board level modifications, PSE's dedicated team of engineers will provide a level of experience and service that far exceed industry standards.

Are the FCC Part 15 rules applicable in Canada?

No, Industry Canada has its own rules for governing the RF spectrum and telecommunications equipment.  Conveniently, the Canadian rules are almost identical to the FCC rules in most areas.  In many cases, compliance to the FCC's Part 15 automatically makes a product compliant to the IC's ICES-003 equivalent.  

One issue to be aware of involves application for formal approval (telecom & transmitters).  An intentional radiator or a telecom device must be registered with the FCC and Industry Canada separately.  The rules that govern these devices are very similar, but each agency will require an individual submittal of applications and supporting paperwork.

How do I test and register a product with the VCCI for Japan?

As the name suggests, the Voluntary Control Council for Interference by Information Technology Equipment, is a voluntary organization which regulates computing devices and peripherals in Japan. The VCCI focuses on the emissions of the product (similar to FCC Part 15 / EN 55022).

A key to this process is that the manufacturer must use a test lab that is a member of the VCCI, like PSE, and the manufacturer must also become a member of the VCCI. The PSE staff is happy to guide clients through the membership process.

Contact:arobbins@pseinc.com

What is the EMC directive?

The EMC directive is just one of many pieces of European legislation designed to produce uniform technical regulations throughout Europe and to foster trade between European countries. Because the standards have been selected mostly from existing international standards it is hoped to have a neutral effect with the rest of the World.

Simply put, the EMC directive requires products to generate no harmful electromagnetic emissions and be immune to defined electromagnetic disturbances and phenomena.

What is EMC?

Electro Magnetic Compatibility is the ability of an electrical / electronic device or system to function reliably in a typical electromagnetic environment (such as an industrial shop floor or a domestic home) while not unduly affecting that environment.

It is not measurable as such, but it is possible to test equipment by monitoring its emissions, or subjecting it to simulated emissions to establish Electro Magnetic Compatibility against internationally recognized standards.

What does the CE marking actually mean?

The CE marking on a product indicates that you are sure your product complies with all the applicable European directives and you can provide evidence if required.

CE marking is not an approval like UL or CSA which always involve third party testing or agency certification.  CE simply indicates the product complies with the directives and applicable standards. Many other Directives may be applicable to a given product and PSE will help determine relevant testing as we assist our clients in attaining the "Marks of Choice."

CE marking artwork?

The CE marking has a very distinct layout and must be a minimum of 5mm high.

CE Artwork Example (282K)

If components in your product are CE marked, do you need additional testing?

The end product (system) must meet the requirements of all applicable directives. The compliance of individual components with the requirements of appropriate European Norms (EN) does not imply compliance of the end product. End product testing ensures that interconnections as well as manufactured CE marked components are performing to what is formally stated in their declaration of conformity.

What products must comply to the EMC Directive?

According to a formal advice document from the European Commission the EMC Directive is applicable to 'electrical and electronic apparatus, as well as to the equipment and installations which contain electrical and/or electronic components'. The term, 'apparatus' has been further defined by the commission as being a finished product delivering an 'intrinsic function' and 'directly usable by the end user', and can be sold as a single commercial unit.

Electronic components do not need marking and the definition of 'component', which has no intrinsic value, has become a major focus of the electronics industry and in some cases is still under discussion.

What are the penalties for non-compliance?

The EMC directive requires the EU member states to take all appropriate measures to ensure compliance.

These agencies will test equipment thought not to comply and if they are proven non-compliant, prohibit sales in Europe. They can even seize products or entire systems.

The person found guilty of knowingly affixing a CE marking to non-compliant equipment is liable to criminal prosecution. The penalty is a fine and up to 6 months imprisonment. 

What is the Low Voltage Directive?

The Low Voltage Directive (73/23/EEC) directs developers to implement safety standards which apply to the products and environment they operate in. It applies to all electrical equipment, designed to operate (normally) in the voltage range 50-1000Vac or 75-1500Vdc.

Can I complete testing required to show compliance to the LVD myself, or must I use a third party lab?

A CE marking according to the Low Voltage Directive is a manufacturer's self declaration of conformity. The manufacturer is obligated by law to be able to support their claim with proof that the product meets the essential health and safety requirements of the directive. This test data can be obtained from a third party, or manufacturers can provide it themselves.

The benefits of using an outside lab include tapping into their expertise, the tractability of the data, and impartial approach.

What do I need to do to sell my product in a specific country?

Most countries have regulations for products entering into their country. PSE provides a high level of knowledge and experience to assist manufacturers in meeting the regulations for specific countries. Regulations present many different conformity assessment options. Some options may allow self-declaration, others may require a manufacturer to obtain third-party certification in order to be accepted into the marketplace.

Your best bet is to consult a compliance professional for advice and assistance.  It like law in the US, you could read up on it and represent yourself in court, but you probably would not be too happy with the results.

Is the c-tick marking mandatory for Australia?

At the time of this writing most product are required to bear the c-tick marking if distributed in Australia.  The market requires emissions testing, similar to the FCC Part 15 in the US.  The distributor must also submit a simple application to the Spectrum Management Agency in Australia for approval to use the marking.  

Do I need the TUV mark in order to ship my product to Europe?

No, there are actually numerous TUV organizations now in existence, all stemming from the German national authority.  They all offer private certifications that utilize the TUV name.  In some cases, a product may see a marketing benefit by having the TUV mark, such as a TUV-GS mark, but it is NOT mandatory.

UL Representatives audit a manufacturer periodically to make sure that a product continues to be manufactured the same way it was manufactured when it obtained UL certification. Factory inspections are unannounced and are conducted on a periodic basis. The UL Representative typically checks random samples of the customer's current production against the product description (Follow-up Service Procedure) written by the engineer who originally evaluated the product. If the product contains materials that are not readily identifiable, UL may conduct sample testing.  Though PSE may provide the engineering, testing and report writing associated with the UL listing of your product, we will not be involved in the factory inspection.  UL will coordinate all follow-up service with your firm directly.

What is the Follow-up Service (FUS) Agreement with UL?

The FUS Agreement is a contract which explains the terms under which the UL Mark may be used. It also explains manufacturers' obligations to continuously monitor their production so their products continue to meet UL's requirements.