Umm…I’m pretty sure it meets regulations. From Metropolis (via LondonParticulars)
For those of you who subscribe to InCompliance magazine (well done, recommended, link here for details) for great articles on EMC, no doubt you’ve read their great “Banana Skins” column. It’s a snapshot of the various odd situations that come up in electromagnetics, including the “Pop-up toasters in Dorset speak Russian,” or “Poorly bonded aircraft surfaces cause loss of navigation and communication in Rain.” As the column notes, the original column started publishing in 1998 in the EMC Journal, and InCompliance has permission from Alan E. Hutley (publisher of the EMC Journal) to continue the tradition.
Keith Armstrong (Cherry Clough Consultants Ltd.) has done a great job compiling the Banana Skin columns. You can find the EMC Journal ones here. They are great examples of why developing and enforcing EMC regulations are necessary, and why regulations always require updating…so that the outliers don’t remain outliers and the world becomes a safer place. There’s also sometimes humor in the “fringe” areas of EMC. Just check out EMI Story 763. Enjoy!
This highway leads to the shadowy tip of reality: you’re on a through route to the land of the different, the bizarre, the unexplainable…Go as far as you like on this road. Its limits are only those of mind itself.
Say, haven’t we been this way before? From Journey to the Center of the Earth, 1959.
This isn’t our first time at this rodeo
Rare Minerals are Surprisingly Abundant.
Kevin Murphy, Rifftrax: “What It Means to Be An American” video commentary
We’ve recently heard that due to the tariffs in play between the United States and China that the latter is threatening to limit access to their rare-earth metal resources. Rare-earth metals are a group of seventeen substances that are mined for their unique properties in technology (electronics, communications, manufacturing, others). Such a limit could severely impact the production of consumer electronics, military equipment and other key product fields.
However, it’s important to note that this is not a new situation. Without the tariffs, a similar situation evolved in 2010 between China, the U.S. and other countries and it was also driven by economics. In that situation the U.S. elected to reopen a domestic rare-earth mine, Molycorp Mountain Pass Mine to alleviate the shortage. While this did help matters, unfortunately the situation flipped again and only a few years later Molycorp had to file for bankruptcy. You can read the details of that time here.
The bottom line may be an old adage but it still holds. Hopefully this time around we remain aware of this cycle and are able to mitigate it somehow.
Those who cannot remember the past are condemned to repeat it.
George Santayana
(As always, the opinions expressed in this article are mine alone and do not constitute legal advice.)
Inverse today presented as one of their “Future 50” Andrés Bernal, a scholar, theorist & activist who crafted the Jobs Guarantee section of the Green New Deal. In the Inverse article, he outlines his history and views on science for the public good, instead of science efforts being based on garnering funds or for later return on investment by corporations.
Regardless of the views on the Green New Deal or on Modern Monetary Theory, I found it refreshing to see how scientists could be recognized for the work they do along with linking their efforts to the public good. There’s counterarguments that can be made for not doing that (Andrés mentions national security and competition incentives), but he makes the case that the pendulum has swung too far to that side and scientific efforts that cannot realize a quick profit or directly link to national security are stifled. In my opinion, the scope of science would then be too narrow and humanity could miss long-term opportunities to improve the planet or the human condition.
It’s worth a read, and I leave you with one of the takeaway quotes:
I believe that providing public resources for the best use of our capacities that ensures quality science is interconnected to an economic bill of rights including universal healthcare, quality public education, the right to dignified employment and working conditions, and the necessary support for scientists and their research not out of fierce competition for funds but as a public good. That is the way we can ensure what economist Yanis Varoufakis calls a future that looks less like the world of The Matrix and more like that of Star Trek.
Andrés Bernal, “Support Scientists Who Work for the Public Good“
(The views in this article are my own or externally referenced, and cannot be considered as legal advice.)
One can be inclined to think that regulations are designed to be inviolable, or that they force a “One size fits all” response by industry. However, we are reminded time and again that regulation is an ongoing balance between desired result and technical feasibility.
A recent example is the chemical DEHP (aka Bis(2-ethylhexyl) phthalate (di-2-ethylhexyl phthalate, diethylhexyl phthalate, dioctyl phthalate, DOP, CAS #117-81-7…OK, let’s go with DEHP). It is a phthalate, chemically inserted amongst the molecular structures of rubbers and plastics like Polyvinyl Chloride (PVC). Its presence promotes the flexibility of those materials and minimizes cracking. All well and good. However, because DEHP is not actually atomically bonded to those materials, it migrates out of the product through its surfaces over time; physical movement and exposure to fluids and gases can increase the migration rate. Studies have indicated that DEHP can negatively affect reproduction and endocrine processes. It is one of the new restricted substances for RoHS, with that restriction going into force this July 22nd.
However, it’s important to note that EU RoHS was designed to accommodate technological exemptions, situations in which substitutions for critical applications aren’t available. Such exemptions are granted when the European Commission agrees with the supporting evidence provided by applicants and stakeholders, with many of the analyses performed by the Oko Institut. The combustion motor industry has applied for a DEHP RoHS exemption (EU/652) , and the proposed exemption is now out for stakeholder comments until June 25th. You can view the proposal here.
The key takeaways are:
You can always apply for technology exemptions. However, you should not apply frivolously just to delay restrictions; applications are meticulously reviewed with as large a scope as possible for impact and frivolous ones will be quickly rejected. Aspects of exemption review are noted in Article 5(a) of the RoHS Directive 2011/65/EU: Decisions on the inclusion of materials and components of EEE in the lists in Annexes III and IV and on the duration of any exemptions shall take into account the availability of substitutes and the socioeconomic impact of substitution. Decisions on the duration of any exemptions shall take into account any potential adverse impacts on innovation. Life-cycle thinking on the overall impacts of the exemption shall apply, where relevant;
Exemptions, when granted come with conditions; make sure your application meets them. Tension is deliberately built into the exemption, with conditions and end-dates, so that industry continues to develop alternative substitutes to the restricted chemicals. For example, the DEHP exemption for combustion motors gives a limit of 30% maximum allowed by weight of the material, what parts can use the exemption, exposure conditions that must be met, and an expiration date of July 21, 2024;
Exemptions are reviewed as part of every RoHS review cycle (about four years) or if circumstances require earlier review. It is possible for exemptions to be moved to an earlier expiration, or changed in scope if substitutes are available earlier for certain parts in scope. Do not assume an exemption will be active in perpetuity if granted.
As with all regulations, adjustments are made whenever possible to accommodate adoption and recognize current technical infeasibilities. It is a tough balancing act to drive movement to safer methods and materials, while not stifling industry innovation and economics.
(Views expressed are mine alone and do not constitute formal legal advice. It is recommended to consult with appropriate authorities for legally binding advice.)
One big happy family. Illustration courtesy of Pedersenscience.com
The threat to a different kind of Relativity.
Definition of relativity 1a:the quality or state of being relative b:something that is relative 2:the state of being dependent for existence on or determined in nature, value, or quality by relation to something else (Merriam-Webster, who may know a thing or two about words)
As part of the UNs Sustainability Development Goals, a recent study has been completed regarding the threat to the variety of lifeforms on Earth, also known as biodiversity. The summary for policymakers (SPM, available here) was approved last week in Paris by the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES). The full 1500-page report is expected out later in the year.
The details are all in the study link above, but the key takeaways are these:
Current global response insufficient; ‘Transformative changes’ needed to restore and protect nature; Opposition from vested interests can be overcome for public good
Most comprehensive assessment of its kind; 1,000,000 species threatened with extinction
(UN SDG Blog May 2019)
On the whole it’s an alarming state of affairs and certainly not a surprise that it was happening (remember saving the spotted owl or snail darter fish?). What is surprising is the scale of the loss. A million species up for extinction certainly should give one pause on how they’re impacting the biosphere.
Note the “Opposition from vested interests” clause, indicating that even with negative impacts confirmed, there will be groups that will want to continue with “business as usual.” My prior blogs (“The Dollars and Senselessness of It” Part 1 and Part 2) described the reasons for this, how this behavior is woven into our current economic structure. The “Transformative changes” referred to by the UN will inevitably include some level of economic restructuring. Also note the other part of that clause, that the opposition “can be overcome for public good,” which is the hope we needed, that it’s not too late.
Preserving our biodiversity will involve regulation. While regulations can be used to meter economic impacts (e.g., taxes and subsidies), oftentimes they are put into place to mitigate humanity’s negative impacts on the planet. Examples include the Endangered Species Act (ESA), Soil and Water Resources Conservation Act (RCA), Clean Air, Clean Water Acts and the Montreal Protocol Treaty (protecting the Ozone Layer). When regulations are properly thought-out and implemented, they work to protect the biosphere (including us) from our negative actions. How rigorously regulations are enforced also determine their effectiveness.
Let us hope we actually take the lesson and set up the right structure for those transformative changes. Biodiversity affects all of us, so it’s going to take all of us to change for the better.
A dirty snowball: ESA Giotto probe’s closeup of the nucleus of Halley’s Comet in 1986. Courtesy spaceref.com. Solar heating and pressure vaporize some of the ice in the nucleus, creating these jets and the icy trail that comets are known for.
Hello everyone, hope you had a chance to view a couple of the Eta Aquarid meteors through this early morning before sunrise!
The answer to “What comet’s debris is the source of the Eta Aquarid meteors?” is one of the more famous ones: Comet Halley. It is of course named after Edmond Halley, the publisher of Newton’s laws on gravitation who in 1705 stated that the comets observed in 1531 (by Apianus) and in 1607 (by Kepler) were actually the same comet which returned roughly every 75 years; he based his statement on orbital calculations made of 24 cometary observations, using Newton’s laws to determine gravitational effects by other planetary bodies. Halley was able to observe the comet himself in 1682. This was the first comet to have been visited by our spacecraft in 1986, and is due to return in 2061.
Earth’s orbit intersects the debris trail left by Halley’s comet twice throughout the year; we will encounter it again in late October, where we’ll be treated to it as the Orionids meteor shower.
(As always, this article reflects my own views and is not to be construed as legal advice…even for comets.)
Hopefully this weekend’s meteor shower ends up less ominous than this …from ScienceNews.org
I hope everyone with a clear sky this Saturday takes some time to check out the Eta Aquarids meteor shower. I personally count it as a win if I see ANY during the weekend, as I live in an area with a lot of light pollution (get out in the country to see the shower best). Although there is a radiant (visual origin point for the shower in the “water jar” part of the constellation Aquarius, you should see meteor streaks throughout much of the sky.
As many of you know, meteor showers result when the Earth passes through a debris field; often from prior passages of a comet when its orbit aligns with Earth’s (the orbit, not the object; otherwise we end up with a Deep Impact/Armageddon situation and I wouldn’t advise going out for viewing at that time).
With all that preamble, here’s the trivia question: From what comet does the Eta Aquarids debris come from?
Just a quick reminder to folks to review the latest proposed/final updates by OSHA to the Nationally Recognized Test Lab (NRTL) program, known as USA/1475 . Comments are allowed until May 10th, 2019.
Main points are that the following changes to the test standards listing were made:
Addition of one for hand tools, (UL 60745–2–23 Hand-Held Motor-Operated Electric Tools—Safety—Part 2–23: Particular Requirements for Die Grinders and Small Rotary Tools);
Updates to a few UL 60950 and UL 61010x standards references, and removal from consideration the AAMI 60601 and 80601 medical device standards (the standards were considered not to involve worker safety and outside the NRTL scope);
Two explosives ISA 60079 standards have also been withdrawn, one of which was incorporated into another final action by OSHA.
UL 1004 (Electric Motors) was withdrawn as UL 1004-1 already captures General Requirements, along with UL 681 and UL 827 (alarm system and central alarm requirements which involve installation, outside of scope).
In addition the scope recognition for six NRTLs (Canadian Standards Association; Intertek Testing Services NA, Inc.; TUV Rhineland of North America, Inc.; TUV SUD America, Inc.; TUV SUD Product Services; Underwriters Laboratories, Inc.) were changed; OSHA expects them to apply for recognition of the UL 1004-1 standard.
Those impacted by the changes should review the actual notice in detail in the Federal Register and provide comment feedback; details on how to do that are in the back of the notice.
Just a quick note regarding the need to be precise when presenting your concerns to ECHA. On April 4th this year, the EU’s General Court (Fifth Chamber) handed down it’s judgement in Case T‑108/17, involving the organization Client Earth as the applicant, the European Commission (EC) as the defendant and the European Chemical Agency (ECHA) as an intervener party. The details are many, but in essence the EC had authorized certain parties to reuse waste PVC (recyclate) to make new PVC articles. PVC articles often contain bis(2-ethylhexyl) phthalate (DEHP) as it makes the product more flexible (e.g., power cords and cabling); the authorization allowed up to 20% of DEHP to be present as an incidental chemical in recycled PVC articles. Client Earth had concerns that the decision process used to grant the authorization was not comprehensive and sought to reverse the authorization. After a very detailed review of the request, the Court decided that the request was unfounded for several reasons, and that the authorization will remain active as is.
Whichever side you’re on with this case, I suggest you read at least one of these judgements to get a sense of the depth of analysis that’s done to make a determination. There are many points addressed in the judgement and it’s clear that the Court takes these matters seriously. Be warned: this is not light reading, but it IS informative.
Here’s the link to the judgment. You can be sure that future cases will also be just as scrutinized to cover all aspects.
An endless tunnel of compliance marks and schemes. Sometimes it seems that way.
the great thing about a standard is…that there’s so many?
If you’ve been involved in Product Safety testing and certification, you may have noticed references to “National Differences.”
“Wait, National Differences? Weren’t we certifying to a harmonized global product safety standard?”
Well, yes you are and no you aren’t. Trust me, this makes more sense as we go along.
First, a quick overview on how major product safety regulations are harmonized.
The World of Certified bodies
Electrical product safety is reviewed by the members of the IECEE, which creates global standards in 23 product categories. Standards are proposed, refined and approved by the IECEE’s member bodies which represent as of this writing 53 countries. As standards are approved and released by IECEE, National Certified Bodies (NCBs), test labs and other regulatory agencies usually adopt them into their own test and certification procedures. Test results and Certificates list the standards to show products have met internationally-recognized safety levels. IECEE member countries also have in place Mutual Recognition Agreements (MRAs), which allow test results and certificates obtained in one country to be accepted at face value in the other country(ies). The advantages of this “CB Scheme” include:
Agreement on safety terms and limits. A product’s test results can immediately be understood by the member country without data translation or manipulation (e.g., pounds to kilograms). Note that while the test methods and results port over, language translation of the text may still be required;
Minimize duplicate testing. If the destination country has the same test standard as the source country and the MRA, then product retesting is not required, saving time and costs;
Non-member countries that do not have their safety standards will often adopt the IECEE’s standards to ensure that imported/exported products have some level of safety testing performed.
In short, the CB Scheme is an excellent way to ensure products consistently meet internationally-recognized safety standards. You can find out more details at IECEE’s site. In an ideal world, that’s all that would be needed. Now let’s meet Reality…
national differences
Despite international efforts to harmonize standards of testing and certification, many times there are additional requirements for products to meet before gaining market access to a country. These additional requirements are known as National Differences, and they are the result of various forces:
New developments in test methods or safety data that were not captured during the last standards development cycle (it can take years for a standard to be developed or updated);
The new version of a standard was not released in time to replace the expiration of the prior standard;
A country implements its own safety or emissions requirements that don’t align with the IECEE standards;
Member countries implements requirements that were presented but not approved or integrated into the standard;
A country elects to maintain pre-existing national regulations that cover more aspects than the international standard, or provides national identity (e.g., the U.S.A.’s Energy Star program);
Unique local logos, language translations of regulatory statements are deemed necessary by the destination country;
In between standards release cycles, IECEE and other technical organizations (e.g., ETSI, CENELEC, CISPR, ISO) develop interim standards which if accepted in the next standards cycle either get incorporated in the next standards update, or become new standards unto themselves. Meanwhile it is up to the NCBs to assess product applications and determine which interim standards to apply. The NCBs must be able to demonstrate how the selection addresses the safety of the product.
covering all the bases
Regulatory engineers and managers can save time and money by understanding National Differences and how they impact their product certification strategy. Make sure that the following areas are addressed during product regulatory assessment and lab and NCB negotiations:
Determine whether the destination countries (where the product will be sold) have a) adopted the IEC or CB certification scheme as-is, or b) have transposed the IEC standard into a slightly-modified version, or c) have released their own unique national standard (For example, there are minor differences between IEC60950-1 and the EU’s EN60950-1. But testing RF to the US FCC CFR47 part 15 requirements do not include safety, while the EU’s Radio Equipment Directive (RED) requirements do include safety aspects).
Most if not all NCBs have the ability to include testing of National Differences worldwide for modest fees. This is a great approach to take when your product’s destination countries require National Differences. Even if the countries don’t have unique requirements, it’s worth considering in case product sales are expanded to other countries later in production.
During review of the lab and/or NCB’s test reports, ensure that the National Differences are referenced by regulation and country. The results of this testing are usually listed towards the back of the report; ensure that the results are included.
Keep in mind that while pre-testing for National Differences saves time and money for destination countries, you will likely need to pay for processing and handling in order to get the destination countries’ certificates of compliance. Even so, the savings in test time and test fees is often worth the extra step of including National Differences testing at the start of product certifications.
While I’ve tried to be accurate in this overview, I’m sure there’s other folks who have their own tips and best known methods for handling National Differences; please feel free to share your tips and methods in your comments.
(NOTE: This article reflects my views and opinions and does not constitute legal advice. Always consult with the appropriate authoritative bodies for legal guidance when assessing your product needs and strategy.)
A View From the Geek Seats 