JANUARY 2019

TM

THE COMPLIANCE INFORMATION RESOURCE FOR ELECTRICAL ENGINEERS

Continuing Your
Professional Education in
2019
PLUS
Brexit and Its Impact on
Market Access

Upcoming Changes to
UN 38.3 Lithium Battery Testing

EMC Concepts Explained

Practical Tips
Hot Topics in ESD
On Your Mark
Banana Skins
In Compliance Magazine
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contributors bruce@brucearch.com ken.javor@emcompliance.com
Keith Armstrong Ken Ross
keith.armstrong@ kenrossesq@gmail.com
cherryclough.com Werner Schaefer
Leonard Eisner wernerschaefer@comcast.net
Leo@EisnerSafety.com
Daryl Gerke
dgerke@emiguru.com

columns EMC Concepts Explained Hot Topics in ESD

contributors Bogdan Adamczyk EOS/ESD Association, Inc
adamczyb@gvsu.edu info@esda.org

EMI/EMC/SI/RF Practical Tips On Your Mark

Arturo Mediano Erin Earley
a.mediano@ieee.org eearley@clarionsafety.com

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JANUARY 2019
Volume 11 l Number 1
CONTENTS
26 CONTINUING YOUR
PROFESSIONAL EDUCATION IN 2019
By the In Compliance Staff

Traditionally, the start of a new year is a time when we reflect

on the progress we’ve made during the year passed and set our
goals for the new year. More often than not, your professional
development goals include training or some form of continuing
education to expand or refresh your technical knowledge. We’ve
queried training resources in our industry to provide you with
an overview of free or affordable solutions to meet your training
goals in 2019. You’ll find here sources of compliance-related
seminars, workshops and other types of training, offered online
and on location, public and private.

36 Brexit and Its Impact on Market Access

By Susanne Wende

This article provides an analysis of the steps that manufacturers

and distributors can take now to help ensure their continued
access to the markets in the 27 remaining European Union
Member States (EU-27) following the exit of the United Kingdom
on 30 March 2019.

44 Upcoming Changes to UN 38.3 Lithium Battery Testing

By John C. Copeland

This article provides information on the changes found in

Amendment 1 to the 6th Edition of UN 38.3, which details
recommended testing to assess potential hazards associated
with lithium-ion batteries in transit.

6 Compliance News 18 Hot Topics in ESD 49 Product Showcase

10 EMC Concepts Explained 20 On Your Mark 50 Advertiser Index

15 EMI/EMC/SI/RF Practical Tips 24 Banana Skins

6 | compliance news
FCC Enforcement Bureau Warns LED Sign Marketers
The Federal Communications Commission (FCC)
is reminding manufacturers and marketers of light-
emitting diode (LED) signs to make sure that their
signs are compliant with FCC rules.
“The FCC takes seriously its responsibility in
ensuring that energy-emitting devices like LED lights
do not interfere with authorized transmissions,” noted
Commission Enforcement Bureau Chief Rosemary
Harold in a press release. Accordingly, “we remind LED
sign marketers of their obligations under the law.”
Radio frequency (RF) energy emitted by LED
signs can interfere with many types of wireless
communications and services. Under FCC rules,
LED signs must be tested and found compliant with
FCC Warns Against Fishing Net Buoys That Use RF
The Enforcement Bureau of the Federal
Communications Commission (FCC) has issued
an Enforcement Advisory in connection with the
marketing, sale or use of fishing net buoys that use
radio frequencies reserved for marine navigation safety
communications.
The Advisory notes that RF-enabled fishing net
buoys are being marketed as devices that can mark
and track fishing nets. However, these devices utilize
frequencies reserved exclusively for automated
identification systems (AIS) used to broadcast and
exchange critical marine vessel information. FCC rules
do not authorize AIS devices for use with fishing nets.
According to the Advisory, the devices, which are
being advertised as “AIS Fishing Net Buoys,” “can
DILBERT © 2018 Scott Adams. Used By permission of ANDREWS MCMEEL SYNDICATION. All rights reserved.
applicable RF limits. LED signs must also include
labeling, identification and user information disclosures
consistent with FCC rules.
According to the press release, the Enforcement
Bureau has investigated hundreds of indoor and
outdoor LED sign models and has observed frequent
instances of FCC rule violations. Since March of this
year alone, the FCC has reached settlement agreements
with 21 separate companies marketing LED signs that
did not conform with applicable FCC requirements.
These settlements have resulted in about $850,000 in
financial penalties paid by the implicated companies,
as well as their commitment to meet all requirements
going forward.
have a serious detrimental effect on maritime safety,
hampering situational awareness of maritime operators
and endangering ships relying on AIS to avoid
collisions at sea.”
The FCC Advisory reminds manufacturers, retailers
and importers of AIS equipment and other marine
equipment to familiarize themselves with all applicable
FCC rules governing equipment authorization and
to immediately cease advertising or selling AIS
equipment that is not certified in accordance with FCC
requirements. The Advisory also reminds parties that
violations of FCC marketing and operating rules can
serve as the basis for significant monetary penalties.

U.S. FCC Chairman Calls on Industry to Join Anti-Spoofing Efforts
As part of its ongoing effort to
help stem the growing problem of
illegal robocalls, the Chairman of
the U.S. Federal Communications
Commission (FCC) has called on
leading phone industry companies
to quickly adopt advanced
technologies that can help to
facilitate validation of inbound
calls and more quickly identify
caller ID spoofing activity.
In letters sent in early November
to AT&T, T-Mobile, U.S. Cellular,
Verizon and at least 10 additional
companies, FCC Chairman Ajit
Pai requested that service providers
provide the FCC with their
timeline for deployment of
the so-called SHAKEN/STIR
framework. SHAKEN/STIR
(an acronym for Signature-based
Handling of Asserted Information
Using toKENs (SHAKEN) and
the Secure Telephone Identify
Revisited (STIR) standards),
provides a mechanism to
authenticate and verify caller
identification for calls carried over
an IP network. The SHAKEN/
STIR framework is the product
of a joint effort between the
Commission and several industry
task forces and has been proposed
for adoption and deployment
in 2019 by the North American
Numbering Council (NANC).
JANUARY 2019 IN COMPLIANCE | 7
Pai’s letter requested that
recipients provide their detailed
responses regarding their plan
implementation timeline to the
Commission by November 19th.
The FCC has been vigorously
enforcing its regulations against
illegal robocalls and spoofing
activities and has issued forfeitures
totaling more than $200 million
since the beginning of 2017.
But Pai believes that adoption
of a robust call authentication
framework by leading service
providers is essential to ending
caller ID spoofing.
8 | compliance news

FCC Reviews Rules on Space Debris

The Federal Communications
Commission (FCC) has taken
action to review its long-
standing rules regarding the
mitigation of debris from satellite
communications systems orbiting
in space.
According to the Commission’s
Notice of Proposed Rulemaking
(NPRM), the value of the global
space economy is now estimated at
nearly $400 billion with investment
in start-up space ventures estimated
at between $2-3 billion in each
of the last three years alone. As a
result, there has been a significant
increase in the number of satellites
in orbit and a concurrent increase
in the amount of orbital debris
that can be generated. Such debris
can directly affect the operational
reliability of new satellite systems.
The Commission’s NPRM
represents an effort to update
and revamp Commission rules
originally implemented in 2004 so
that they more fully reflect both
the Commission’s experience in
the satellite licensing process as
well as improvements in mitigation
guidelines and practices.
Notably, the NPRM also denied
an 18-year old petition to apply
the FCC’s orbital debris mitigation
requirements to amateur radio
service satellites, noting that
“numerous licensees, including
amateur satellites operating in
LEO (low-earth orbit), have
successfully satisfied our orbital
debris mitigation requirements.”

FCC Updates HAC Requirements

The U.S. Federal Communications Commission
(FCC) has modified its reporting and consumer
communications requirements regarding hearing
aid-compatible (HAC) wireless handsets.
In a Report and Order issued in mid-November, the
Commission adopted the following modifications to its
current HAC requirements:
• Service providers must now post on their publicly-
available websites information about HAC wireless
handsets that is currently submitted annually to the
FCC on Form 655;
• Service providers must certify annually that they
are in compliance with all FCC rules applicable to
HAC handsets; and
• Eliminates the requirements that service providers
file FCC Form 655 annually with the FCC,
while continuing to require the filing by handset
manufacturers.
According to FCC Chairman Ajit Pai, the changes
“will enable consumers to obtain the relevant
information they need about the availability of hearing
aid-compatible devices” while “also allow(ing) the
Commission to ensure compliance with minimal burden.”

You Can’t Make This Stuff Up! Will Electric Cars Make AM Radio Obsolete?

Electric-powered automobiles may offer many
important advantages over conventionally-powered
vehicles when it comes to environmental considerations.
But they may also lead to the demise of AM radio.
According to a recent article in the Wall Street
Journal, manufacturers and consumers are finding
that the electromagnetic frequencies generated by the
vehicles’ electric-powered motors occupy the same
wavelength as AM radio signals. As a result, AM
radio signals are fully or partially blocked even before
they reach the onboard antenna. At best, drivers and
passengers get radio reception full of static. But, as
electric engines become more powerful, AM radio fails
to work at all.
Rather than searching for a solution to the problem,
several electric vehicle manufacturers, including Tesla,
BMW and Honda, have reportedly removed AM radio
capabilities from their vehicles altogether, assuming that
FM and satellite radio stations and streaming from in-
vehicle smart phones will fill the void. But woe to those
drivers who have fond memories of listening to an ever-
changing array of AM radio stations as they traveled
across the country in wood-paneled station wagons!
 JANUARY 2019 IN COMPLIANCE | 9

FDA Issues Updated Guidance on FDA Releases Draft Guidance of

Medical Device UDI Compliance Medical Device Cybersecurity

The U.S. Food and Drug Administration (FDA)
has issued an updated Guidance on its unique device
identification (UDI) labeling requirements for
medical devices.
Under the terms of the Guidance, which was
issued in early November, device manufacturers
of most Class 1 and unclassified medical devices
will be allowed to continue to market UDI devices
manufactured prior to the implementation date of
the FDA’s new UDI labeling and data submission
requirements, even if the labeling of those devices
does not conform with the FDA’s labeling
requirements.
The change is intended to provide device
manufacturers with more flexibility regarding the
disposition of UDI medical devices in inventory that
do not bear the required labeling.
FDA rules regarding labeling and data submission
requirements applicable to UDI systems in most
Class 1 and unclassified medical devices are intended
to facilitate submission and posting of listings to
the Global Unique Device Identification Database
(GUDID) for UDI systems. Although these
requirements were due to be phased in starting this
past September, the FDA now says that it does
not intend to enforce the requirements prior to
September 2022.
The U.S. Food and Drug Administration (FDA) has
issued a series of recommendations for medical device
manufacturers whose devices may be susceptible to
cybersecurity risks.
The FDA’s draft guidance “Content of Premarket
Submissions for Management of Cybersecurity in
Medical Devices” updates information provided by the
FDA in 2014 and details revised recommendations
for device design, labeling and documentation to be
included as part of premarket submissions for at-risk
medical devices. The updated guidance is intended to
address the rapidly-evolving cybersecurity landscape, as
well as an increased understanding of actions that can
be taken by device manufacturers to mitigate the threat.
The FDA is hosting a public workshop January 29-30
to discuss specific aspects of the draft guidance in
detail. Further information about this workshop,
including registration instructions, is available at
https://www.fda.gov.
Errata
The article “What Every Engineer Needs to Know
About: Filters” that ran in the October 2018 issue of
In Compliance on pages 68-73 previously appeared in
Interference Technology March 2018 EMC Fundamentals
Guide. To view the updated version of this article please
visit: https://incompliancemag.com/article/filters.

You Can’t Make This Stuff Up! Kilograms, Amperes and Kelvins, Oh My

Just when you thought that some
things were forever immutable, now
comes word that the definitions of
some critical weights and measures
will soon be changed.
According to a report posted to
Science Daily website, the General
Conference on Weights and
Measures voted in November to
redefine the international system of
units (SI), resulting in changes in
the definition of the kilogram, the
ampere, the kelvin and the mole. As
of May 2019, these measurement
units will no longer be defined by
actual physical objects, but instead
“in terms of constants that describe
the natural world.”
Specifically, the changes are:
• Kilogram—will be defined by the
Planck constant (h)
• Ampere—will be defined by the
elementary electrical charge (e)
• Kelvin—will be defined by the
Boltzmann constant (k)
• Mole—will be defined by the
Avogadro constant (NA)
The changes are reportedly
intended to “assure the future
stability of the SI and open the
opportunity for the use of new
technologies, including quantum
technologies, to implement the
definitions.”
10 | EMC concepts explained

IMPEDANCE OF THE FOUR PASSIVE CIRCUIT

COMPONENTS: R, L, C, AND A PCB TRACE

By Bogdan Adamczyk and Jim Teune

T
his article investigates the impedance of the three
standard passive circuit components (R, L, and C) as well Dr. Bogdan Adamczyk is a
professor and the director
as the frequency response of a PCB trace. It is shown that of the EMC Center at Grand
a PCB trace can be modeled as a resonant RLC network just like Valley State University
the standard components and effectively constitutes the fourth (http://www.gvsu.edu/
circuit component whose frequency behavior directly effects the emccenter) where he performs
research and develops EMC
impedance of the resistors, inductors, and capacitors on a PCB. educational material. He is an
iNARTE certified EMC Master Design Engineer,
1. COMPONENT MODELS AND SIMULATIONS a founding member and the chair of the IEEE
EMC West Michigan Chapter. Prof. Adamczyk
Actual circuit components exhibit non ideal effects that can is the author of the textbook “Foundations of
be modeled by augmenting the ideal model with a parasitic Electromagnetic Compatibility with Practical
Applications” (Wiley, 2017). He can be reached
resistance, inductance and capacitance. The parasitics for the
at adamczyb@gvsu.edu.
three standard components (R, L, and C) considered in this
section come from the component itself and not from the
connecting traces. The parasitics associated with a PCB trace Jim Teune is a founding
considered in this section come from the trace itself and not from partner of E3 Compliance
LLC which specializes in
the other circuit components. product development and
EMC precompliance testing.
1.1 Resistor He is an iNARTE certified EMC
Engineer and Master EMC
Circuit model and the impedance vs. frequency curve (straight- Design Engineer. Jim is an
line approximation) for a resistor and its parasitics (with no traces industrial partner of the EMC Center at GVSU.
attached) are shown in Figure 1 [1]. He can be reached at jim@e3compliance.com.

Figure 1: Resistor circuit model and its impedance curve

 JANUARY 2019 IN COMPLIANCE | 11

The parasitic inductance and capacitance in Figure 1 1.4 PCB Trace

are inherent to the component itself and the Figure 7 on page 12 shows the circuit models and the
fabrication method, and are not attributed to the impedance curves for two PCB traces of length 0.75
connecting traces. Figure 2 shows the simulation and 2.5 inches, respectively.
results for a 300-Ω surface mount resistor together
with its realistic parasistics (simulation is run between
1 MHz and 1 GHz).

The low-frequency impedance

stays at 49.5 dB and drops by
1 dB at 1 GHz. The self
resonant frequency is well above
1 GHz and thus not shown in
the simulation. This simulation
result will be confirmed in the
measurement section.

1.2 Inductor
Circuit model and the
impedance vs. frequency curve
for an inductor with its parasitics
(with no traces attached) are
Figure 2: Resistor with its parasitics - impedance vs. frequency (no connecting traces)
shown in Figure 3.

Figure 4 shows the simulation

results for a 220-nH inductor
together with its realistic
parasistics.

The self-resonant frequency of

the inductor is 638.2 MHz –
this result will be confirmed in
the measurement section.

1.3 Capacitor Figure 3: Inductor circuit model and impedance curve impedance vs. frequency (no connecting traces)
Circuit model and the impedance
vs. frequency curve for a
capacitor with its parasitics (with
no traces attached) are shown in
Figure 5 on page 12 [2].

Figure 6 on page 12 shows the

simulation results for a 120-pF
capacitor together with its
realistic parasistics.

The self-resonant frequency of

the capacitor is 995.2 MHz –
this result will be confirmed in
the measurement section. Figure 4: Inductor with its parasitics - impedance vs. frequency (no connecting traces)
12 | EMC concepts explained

Comparison of these curves

with the one in Figure 4 reveals
that an unpopulated PCB trace
acts as an inductor! The longer
trace has larger inductance
and hence its self resonant
frequency is lower than that of
the shorter trace.

These are two very important

observations since in any
practical circuit, the standard
Figure 5: Capacitor circuit model and impedance curve
three passive components (R,
L, and C) will be connected
to other components with
PCB traces. These traces
will act as the fourth circuit
component whose impact will
depend on its trace length.
The measurement section will
illustrate this impact.

2. IMPEDANCE
MEASUREMENTS
The experimental boards used
for impedance measurements
are shown in Figure 8 [3].

The measurement setup is Figure 6: Capacitor with its parasitics –impedance vs. frequency (no connecting traces)
shown in Figure 9.

2.1 PCB Trace

Figure 10 shows the
impedance measurement of
two unpopulated PCB traces
of length 0.75, and 2.5 inches,
respectively.

Note that the results in

Figure 10 are consistent
with the simulation results
in Figure 7. The short trace
resonates at 1 GHZ while
the long one resonates at a
frequency of 559.8 MHz.
This behavior is the direct
consequence of the increase in Figure 7: PCB traces with their parasitics - circuit model and impedance vs. frequency
the trace inductance. (no components attached)
 JANUARY 2019 IN COMPLIANCE | 13

Figure 8: PCB boards used for impedance measurements Figure 9: Measurement setup

2.2 Resistor
Figure 11 shows the impedance
measurement of a 300-Ω
resistor with no connecting
traces and with the PCB traces
of length 0.75, and 2.5 inches,
respectively. (Resistor used is
Stackpole Electronics, Inc.
RMCF0805JT300R).
Figure 10: PCB Trace – impedance measurements: a) short trace, b) long trace
Note that the result in
Figure 11a is consistent
with the simulation result in
Figure 2. When the resistor
is attached with a short PCB
trace, the 3-dB point moves
from the GHz range to the
frequency of 835 MHz. As
the trace length increases,
this point moves to the left
(522 MHz), which is the direct
consequence of the increase in
the trace inductance.

2.3 Inductor
Figure 12 on page 14 shows
the impedance measurement
of a 220-nH inductor with no
connecting traces and with
the PCB traces of length 0.75, Figure 11: Resistor – impedance measurements with: a) no trace, b) short trace, c) long trace
14 | EMC concepts explained

and 2.5 inches, respectively. (Inductor used is Murata, REFERENCES

LQG18HHR22J00).
Note that the result in Figure 12a is consistent
with the simulation result in Figure 4. When the
inductor is attached with a short PCB trace, the self
resonant frequency point moves from 638.2 MHz
to 559.5 MHz. As the trace length increases, this
frequency shifts to the left, to 278.6 MHz, which is
the direct consequence of the increase in the trace
inductance.
1. Bogdan Adamczyk, Foundations of Electromagnetic
Compatibility with Practical Applications, Wiley, 2017.
2. Adamczyk, B., Teune, J., “Impact of a Trace
Length on Capacitor Frequency Response,”
In Compliance Magazine, March 2018.
3. Bill Spence and Pete Vander Wel, “Designers
of the PCB used for impedance measurements,”
Gentex Corp, 2008.

What is noteworthy here is

the fact that the inductor
connected with a short
trace resonates at the same
frequency as the unpopulated
long PCB trace itself! This
result supports the simulation
conclusion in Section 1.4: an
unpopulated PCB trace acts as
an inductor!

2.4 Capacitor
Figure 13 shows the
impedance measurement of
a 120-pF capacitor with no
connecting traces and with
the PCB traces of length 0.75,
and 2.5 inches, respectively. Figure 12: Inductor – impedance measurements with: a) no trace, b) short trace, c) long trace

(Capacitor used is Murata,

CGM1885C1H121JA16).

Note that the result in

Figure 13a is consistent
with the simulation result in
Figure 6. When the capacitor
is attached with a short
PCB trace, the self resonant
frequency point moves from
993.2 MHz to 612.4 MHz. As
the trace length increases, this
frequency shifts to the left, to
117.5 MHz, which is the direct
consequence of the increase
in the trace inductance.
Additionally, an anti-resonance
point is present at 901.5 MHz
frequency. Figure 13: Capacitor – impedance measurements with: a) no trace, b) short trace, c) long trace

AVOID CRITICAL SIGNALS
IN EDGES OF THE PCB
By Arturo Mediano
When routing a printed circuit board (PCB), try to avoid critical signals in emissions
or immunity close to the edge of the board to create a more robust system for
EMI and EMC.
I
n the design of a PCB a critical task is to identify
critical signals for emissions and immunity. For
emissions, those signals are for example digital
signals (i.e. clocks), high dv/dt or di/dt signals, RF,
etc. For immunity, we consider resets, interruptions,
low level analog signals, etc.
When those signals are identified, avoid routing them
close to the edge of the board especially if a ground
plane is not correctly located below the signal.
In Figure 1 an example with a critical signal for
emissions is presented. The signal forward path is in top
layer close to the edge of the board and the return path
in bottom layer is not located below the signal with full
coverage. The fringing effect creates a very hot area with
possibilities to radiate and/or create coupling problems
to nearby circuits, cables, or slots in enclosures.
EMI/EMC/SI/RF practical tips | 15
Arturo Mediano received his M.Sc. (1990)
and his Ph. D. (1997) in Electrical Engineering
from University of Zaragoza (Spain), where
he has held a teaching professorship in EMI/
EMC/RF/SI from 1992. He is the founder of
The HF-Magic Lab®, a specialized laboratory
for design, diagnostic, troubleshooting, and
training in the EMI/EMC/SI and RF fields at
I3A (University of Zaragoza). Arturo can be
reached at a.mediano@ieee.org.
To minimize this effect we have two possibilities
as shown in Figure 2. You can separate the trace
from the edge and include a ground plane below the
trace (left) or you can include an additional trace in
top layer along the edge of the board connected to
the ground planes with vias (right). In this way, the
electromagnetic activity is contained inside of the PCB
(the fringing effect is reduced).
16 | EMI/EMC/SI/RF practical tips

Figure 1: The effect of critical signals in the edge of boards.

Figure 2: How to minimize the fringing effect.

I have prepared a simple experiment to

visualize this problem in the laboratory.
A small PCB with two layers has been
manufactured as explained in Figure 3.

Two cases will be compared: i) a top

trace close to the edge of the board
and without a complete ground plane
below it (top figure), and ii) a top trace
separated from the edge of the board and
with a good ground plane below it.

The board was manufactured as in

Figure 4 where our signal (a digital
clock) is introduced in connector
K8.1 and a resistor R8.1 is the load.
The bottom layer (not shown) has
the ground plane with limit in the
dashed line labeled as “GND EDGE
ON BOTTOM LAYER”. The two
situations to be compared are selected
with jumpers JP8.1 and JP8.2. Figure 3: Basic description of the PCB in our experiment.
 JANUARY 2019 IN COMPLIANCE | 17

The activity measured below the PCB with a spectral
scan is shown in Figure 5. Note the harmonics of the
clock and some signal in the 100MHz band related with
FM broadcasting ambient noise. The difference between
a trace close to the edge (left) and a trace far from the
edge (right) is in some harmonics more than 20dB.
My final advice: NEVER route a critical signal close
to the edge of the board. Our example was related
with emissions but a fully equivalent situation can
be described considering the signal is critical for
immunity.

Another interesting result is the

measurement of magnetic field
in a spatial scan as shown in
Figure 6.

For the case of trace close to

the edge the hot area is clearly
identified in red color, a very
dangerous area to locate close
to cables or sensitive areas of
your product. Additionally some
emissions can be radiated especially
in the UHF frequency band for
typical size of electronic products. Figure 4: The board in our experiment.

Figure 5: Spectral activity close to the PCB: with trace close to the edge (left) and far from the edge (right).

Figure 6: Spatial activity close to the PCB: with trace close to the edge (left) and far from the edge (right).
18 | hot topics in ESD
ESD FROM WITCHCRAFT TO SCIENCE
By Dr. Jeremy Smallwood for EOS/ESD Association, Inc.
A rthur C. Clarke formulated three laws (1) which
can be adapted for electrostatics and ESD use:
1. When an expert states that something is possible,
they will often be right. If they state that something
is impossible, they are quite possibly wrong.
2. To discover the limits of the possible we only need
to venture a little way past the usual.
3. Any technology with which we are not familiar is
indistinguishable from magic.
Experience has convinced me that the first and second
are valid. I learned long ago the hard way not to say (at
least in front of a client) that something is impossible.
My conversations with some unfortunate industry
practitioners who have been instructed to sort out their
company ESD program tells me that for many people
the third is true also.
In psychology, the “conscious competence” learning
model has been devised which relates to stages in the
progress of learning (2). These can be summarized as
Stage 1: Unconscious incompetence - The learner does
not understand or know how to do something and
may not see the need to do it. To progress, they must
recognize their own incompetence and the value of the
new skill before moving on to the next stage.
Stage 2: Conscious incompetence - The learner does
not understand or know how to do something but they
recognize the need and value of it. Making mistakes
can be an essential part of the learning process.
Stage 3: Conscious competence - The learner is now a
practitioner who knows how to do something but this
requires heavy conscious involvement.
Stage 4: Unconscious competence. The practitioner’s
skill has become “second nature”. It may even be
performed while executing another task. They may be
able to teach it to others.
Dr. Jeremy Smallwood (BSc CEng MIET CPhys
FInstP) has over 60 publications in the fields
of electrostatics, measurements, ESD ignition
hazards and ESD prevention and is a regular
speaker at international conferences and
workshops. He works in British Standards and
IEC panels on handling of electrostatic sensitive
devices and control of undesirable static electricity.
Founded in 1982, EOS/ESD Association, Inc. is a
not for profit, professional organization, dedicated to
education and furthering the technology Electrostatic
Discharge (ESD) control and prevention. EOS/ESD
Association, Inc. sponsors educational programs,
develops ESD control and measurement standards, holds international
technical symposiums, workshops, tutorials, and foster the exchange of
technical information among its members and others.
It is easy to see how this model reflects the growth in
understanding of ESD control and our ability to develop
effective ESD control programs in the electronics
industry. In the late 1970s ESD was a new issue scarcely
recognized or believed by most in the industry (Stage 1).
Over the next decade or so various individuals and
organizations worked to demonstrate ESD risks and
understand them, learning to specify ESD control
programs and make ESD control equipment and
materials, and writing the first Standards relating to
ESD control (Stage 2).
Mistakes were made and these led to learning and
development of the field. Conferences and knowledge
sharing via the ESD Association and Symposium
and other routes, led to much wider dissemination of
knowledge and practice of ESD control techniques.
There gradually arose many individuals and
organizations at Stage 3.
The number increased over subsequent decades. We can
now attend tutorials given by expert practitioners and
even get Certification as a means of recognition of our
competence.
Yet, in my practice as a consultant I still come across
individuals and organizations who are at Stages 1 and 2.
 JANUARY 2019 IN COMPLIANCE | 19

Those at Stage 1 often believe ESD is not a real issue
for them. Many feel being forced to adopt what may
be perceived as unnecessary or over the top ESD
control measures because their customers require them
to do so. Often, they will state that they don’t get
ESD failures. Whether or not this is correct is open to
discussion, but if asked whether they analyze failures
for ESD damage they usually reply that they don’t.
If they do have ESD failures, they would not know
about them.
ESD control investment made by those at Stages
1 and 2 is often regarded by them as money
wasted. Ironically, they may be right, because their
ESD control measures applied with insufficient
understanding may be ineffective. As an example,
grounding personnel is an essential ESD control
measure in manual handling of ESDS. One
organization had a serviceable ESD control floor
that represented a serious investment. Personnel
can be effectively grounded through a footwear and
flooring system, but both ESD control footwear and
flooring that work together as a system are necessary
for effectiveness. They had decided not to issue their
personnel with ESD control footwear as it was
regarded as expensive and unnecessary.
In fact, I was hardly able to find any
equipment that was grounded through
the floor – this expensive, potentially very
useful facility was completely wasted.
essentially made of easily charged insulating materials,
or how to measure electrostatic properties of minute
features of some modern ESD protective packaging.
ESD control will move increasingly from the realms
of magic to applied science, as more of us move into
Stage 3 learning. We should now know how every
piece of ESD control equipment we use works as
part of the ESD control program, why we selected it
and how we will detect when it fails. Investment in
knowledge and understanding may be among the best
ESD control strategy we can make. We wouldn’t try
to control our finances by magic, so why would we
attempt to use it in our ESD control program?
REFERENCES AND FURTHER READING
• Wikipedia, Clarke’s Three Laws,
https://en.wikipedia.org/wiki/Clarke%27s_three_laws.
• Wikipedia, The Four Stages of Competence,
https://en.wikipedia.org/wiki/Four_stages_of_
competence.
• Smallwood J., Taminnen P., Viheriaekoski T.,
(2014) Optimizing Investment in ESD Control,
Proc. EOS/ESD Symp., EOS-36, Paper 1B.1.

None of us, I believe, are fully in Stage

4 in ESD control. Those at the forefront
move fluidly between Stages 2, 3 and 4
as new manufacturing and ESD control
technologies emerge, and we detect and
evaluate new risks and propose new
solutions. ESD control standards continue
to evolve as we better understand ESDS
sensitivity and ESD threats, and how to
control them. The most sensitive ESDS and
novel processes often may need recognition
of unusual ESD risks and non-standard
control measures. ESD will continue to
surprise us regularly with issues that seem
to be impossible, either in how they happen
or how they may be controlled. Examples
are the challenge of preventing charging
and damage to flat panel displays which are
20 | on your mark
UNDERSTANDING RISK ASSESSMENT
By Erin Earley
This month, we’ll look at risk assessment, a fundamental element not only of labeling, but of the
overall safety of your products
R isk assessment is fundamental when it comes to
machine and product design – as well as safety. You
can’t design out a risk, safeguard a hazard or warn about
a risk unless you first assess it. A thorough risk assessment
will identify potential risks and control actions related
to them to protect those who interact with your product
during its anticipated lifecycle. It’s important to have a
complete understanding of the risk assessment process, why
it’s needed, and when it’s needed in order to understand
your requirements and the safety and liability impact.
DEFINING RISK – AND WHEN RISK
ASSESSMENT IS NEEDED
What is risk? Why and when do we need to assess it?
ANSI B11.TR3, part of the ANSI B11 series of
technical reports and standards pertaining to the
design, construction, care and use of machine tools,
provides us with these helpful definitions:
• Hazard: A potential source of harm
• Risk: A combination of the probability of occurrence of
harm and the severity of that harm
• Risk assessment: The process by which the intended use
of the machine, the tasks and hazards, and the level of
risk are determined
• Residual risk: Risk remaining after protective
measures have been taken
At its core, risk assessment is a process where hazards
are identified, the severity of injury presented by each
hazard is estimated, and the probability of occurrence
of the injury is estimated. For risks that are considered
“unacceptable” based on the standards, regulations
and laws that apply to the area at hand – as well as
opinions of your organization – safeguards or control
measures are needed to reduce the risk. This involves
either eliminating the hazards or controlling those
risks that can’t be eliminated to minimize injury and
illness potential.
This article is courtesy of Clarion Safety Systems ©2019. All rights reserved.
Erin Earley, head of communications at
Clarion Safety Systems, shares her company’s
passion for safer products and workplaces.
She’s written extensively about best practices
for product safety labels and facility safety
signs. Clarion is a member of the ANSI Z535
Committee for Safety Signs and Colors, the
U.S. ANSI TAG to ISO/TC 145, and the
U.S. ANSI TAG to ISO 45001. Erin can be
reached at eearley@clarionsafety.com.
Risk assessments can help manufacturers improve
product/equipment safety, reduce risk and comply
with applicable legal requirements. From a legal
perspective, “reasonably foreseeable” risks must be
defined as well as “reasonable” ways to mitigate risks
associated with hazards that cannot be designed out.
It’s critical to proactively prioritize and mitigate risk
in advance of injuries or catastrophes. This process
is your means to evaluate your product’s foreseeable
risks at stages that you determine. With risk
assessment, potential hazards can be identified with
solutions provided as early as possible in the product’s
lifecycle. This can be done during the concept stage
of the product’s design, during the final stage of
design, prototype production and testing, on a final
manufactured product, and after placement in the
market if an accident occurs or if an unforeseen safety
concern arises. See Figure 1.
KEY STANDARDS TO FOLLOW
For consistency and to utilize the latest advances in
this area, following a standards-based risk assessment
process is important. Recent risk assessment standards
from ANSI and ISO exemplify today’s best practices
in this field. These are useful tools to help prioritize
risks and examine ways to reduce them, with
helpful annexes for analyzing hazards and defining
risk severity levels. The methods outlined in these
standards can be tailored to become your team’s
standardized process for product risk evaluation.
 JANUARY 2019 IN COMPLIANCE | 21

Best practice standards in this field include:
• ANSI Z10 Occupational Health and Safety
Management Systems standard
• ANSI B11.0 Safety of Machinery; General
Requirements and Risk Assessment
• ISO 31000 Risk management – Guidelines
• ISO 31010 Risk management – Risk assessment
techniques
• ISO 12100 Safety of machinery – General principles
for design – Risk assessment and risk reduction

Figure 1: An example of how risk assessment can be used throughout a product’s lifecycle
22 | on your mark

Keep in mind as well that there are a number of
industry standards requiring risk assessments that
may provide additional insight, including – among
many others – machinery, packaging machinery,
semiconductor equipment, electrical systems, fire and
consumer products.
THE RISK ASSESSMENT PROCESS
When it comes to product safety, potential risks must
be identified, and then a determination needs to be
made as to whether they’re designed out, guarded or
warned about.
From a legal perspective, you must also define what
hazards are “reasonably foreseeable” and “reasonable”
ways to mitigate risks associated with hazards that
cannot be designed out. The typical process is:
• Identify hazards
(see the hierarchy of controls in Figure 2) machine
builders lose out completely on the most effective
means for risk reduction if they don’t consider ways to
reduce the risk as early as possible. Some inherently
safe design measures are very simple, like ensuring
that sharp corners and edges are broken (radiused), or
that the clearances between moving parts and fixed
parts are large enough that fingers and hands can’t be
trapped or crushed. Other methods are more complex,
like using sound engineering techniques when
designing the electrical or fluidic control systems.
These are all methods that can’t be used once the
machine is finished.”
ANSWERING COMMON QUESTIONS
From his experience working with clients, Nix says
that two of the big picture questions he’s commonly
asked are:

• Assess risk 1. Isn’t a risk assessment a potential liability

nightmare if discovered during a product liability
• Reduce risk lawsuit?
• Document results 2. How do I use risk assessment to determine what
• Reassess the risk risk control measures I need?

“When it comes to the safety

of any machine, the critical
stage for risk assessment is at
the beginning of the design
cycle, even if this means that
the machine is just an idea on
a napkin. Identifying hazards
and thinking about risk
mitigation can start as soon
as the design process begins,”
says Doug Nix, managing
director of Compliance
Insight Consulting, which
provides regulatory,
machinery safety analysis,
consulting and training
services to clients. He also
leads the Machinersafety101
blog and podcast to spread
resources and best practices
for machine safety.

“Since the first level of the

hierarchy of controls is
‘Inherently Safe Design,’ Figure 2: An example of the hierarchy of controls, based on ISO 12100
 JANUARY 2019 IN COMPLIANCE | 23

It may seem like documentation that proves your product had inherent risks would
be detrimental in a liability lawsuit. However, the opposite is true. A formal, well-
documented risk assessment program supports a product liability defense position
should an accident and lawsuit occur.

The answer to the first, Nix says, is “Absolutely not. The bottom line: to effectively identify, mitigate and
If a risk assessment is well done, it shows that the communicate about risks, assessments need to be
company was trying to do the right thing, taking taken seriously, and viewed as an ongoing process to
proactive steps to protect people.” improve safety.

It may seem like documentation that proves your
product had inherent risks would be detrimental in
a liability lawsuit. However, the opposite is true. A
formal, well-documented risk assessment program
supports a product liability defense position should
an accident and lawsuit occur. It shows your efforts to
reduce risk and the “reasonableness” of the decisions
you made to make your product safer, including the
method used to develop the labels that were needed to
communicate essential safety information.
When it comes to the second question, “Apply
the hierarchy of controls following the initial risk
assessment, then iterate the risk assessment to
decide if enough risk reduction has been achieved
and if anything more needs to be done. Risks not
fully mitigated by inherently safe design measures
or engineering controls require the use of hazard
warning signs and labels and other information for use
(manuals, lights, bells, buzzers, etc.),” Nix says.
“Risk assessment should start at design and then be
iterated at each major step in the design, build and
installation of the machinery. Once the machine
is commissioned, the workplace should take the
machine risk assessment and use it as the basis for
the workplace job hazard analysis to determine the
specifics of staffing (such as the need to rotate workers
through specific tasks due to ergonomics issues), PPE,
and training,” says Nix.
With better risk communication comes the possibility
of significantly reducing injuries and deaths in the
workplace.
Stay tuned for our next article in the On Your Mark
series for an in-depth interview with Doug Nix on
more practical implications of risk assessment and your
products – including exploring his ‘field guide to bad risk
assessments’ to help you identify steps that may be needed to
make improvements to your processes.

AVOIDING COMMON RISK ASSESSMENT

PITFALLS
Nix also sees common pain points or struggle areas
with clients performing risk assessments. These
include:
• Using outdated risk assessment methods, instead
of current hazard-based and standards-based
assessments
• Risk assessments being done by a single person
rather than a team
• Risk assessment done ‘for form’ and then filed away
without any action taken
24 | banana skins
Banana Skins
142 Intermodulation of two
broadcast transmitters
interferes with automatic garage doors
We have news from down-under about
things that bump and grind in the night...
Australia’s ABC TV and Sydney’s
new FM radio station ‘Nova 96.9’
have unwittingly joined forces to
meddle with automatic garage doors.
VK2WI reports that hundreds of
radio-controlled garage doors across
Sydney have been overloaded by the
ABC and Nova transmissions and
some are refusing to open and close. In
several cases the doors have developed
a life of their own, randomly opening
and closing at all hours. The reason
is that Nova broadcasts on 96.9MHz
and the ABC TV sound signal is on
69.75MHz.
When the two signals mix in an
overloaded door receiver, the result
is a 27.15MHz signal, which passes
straight through most door receivers
which are tuned to 27.145MHz, only
5kHz different. This causes erratic
behaviour, dependent upon signal
content, and the doors open and close
in sympathy. Perhaps the designer has
sleepless nights, too!
(From Graham Eckersall G4HFG /
W4HFG 6th July 01, who got it from
the ‘News’ section of the RSGB website,
www.rsgb.org.)
143
Radio transmitters
interfere with photographic
cameras
Subject: Bizarre Solution... What
you describe is a common problem
to commercial-radio technical folk.
Proximity to active radio-transmitting
antennas can cause really wild things to
happen to electronic circuits such as the
metering portions of your 645 Pro. (It’s
interesting to note that even some very
well-designed and expensive electronic
test equipment can be rendered
essentially useless by these strong radio-
frequency fields.)
The wiring within your camera (it may
be nothing more than a centimetre or
so of printed-circuit land on a fiberglass
circuit board) acts as an antenna. The
signal it picks up can then be rectified
(changed from a radio signal to a small
D.C. voltage) and this voltage can,
in turn, add to or subtract from the
small voltage generated or controlled
by the light-sensing elements in your
camera metering system. I would guess
that if it adds, you get underexposure;
if it subtracts, you get overexposure.
It will depend upon exactly how the
rectification occurs in the camera circuit.
A parallel case of this type of
interference occurs when an automobile
with a radio-controlled door lock is
located near a high-powered radio or
television transmitting tower. Often, it’s
impossible to unlock the car using the
small, keychain-type device because of
the same type of effect. In some cases,
a particular program signal will trigger
the car alarm! The tops of some of
those California hills are loaded with
radio transmitters and can contain very
strong radio-frequency (RF) fields.
It would be my guess that the metal
housings of some cameras would shield
the internal electronics from RF effects.
Of course, a plastic housing offers little
such shielding. At best, even a metal-
bodied camera would be subject to
“radio interference.” It can be pretty
squirrely stuff! Radio signals and light
are both forms of electromagnetic
radiation and the inverse square law
works for both. The best cure, therefore,
is increasing the distance between your
camera and the transmitters. As a radio
engineer, I’ve learned long ago that
you just can’t do certain things close in.
Hope this simple explanation helps.
(David Mehall, 22 Aug 1996, from an
email thread on photography.)
144 Video surveillance system
interferes with car central
locking and security
Gun Wharf, a leisure centre in
Portsmouth, opened in Easter 2001.
It had an underground car park, and
the car park had a video surveillance
system. It seems that electromagnetic
emissions from the video system would
often interfere with car central-locking
and security systems – locking the cars
as soon as they were unlocked, or just
not allowing them to be unlocked at
all. Many people had to leave their cars
in the car park and take taxis home.
(From Anne Cameron, Alenia Marconi
Systems, 6th July 01)
145
Electromagnetic weapons
could be used for
Information Warfare
A relatively recent (1997) definition
of Information Warfare given by
the Ministry of Defence is: “The
deliberate and systematic attack on
critical information activities to exploit
information, deny services to the
authorised user, modify and corrupt
data.” The issues involved reach well
beyond the realm of military warfare,
extending to e-business, e-commerce,
e-finance and e-government. The
power, water and food distribution
systems, the emergency services, air
traffic control systems, the banking
sector and the financial markets, to
name but a few, are all dependant on
networked digital systems for effective
communication and control.
It is a sobering reflection that ‘the
most advances society in the world
is really only four meals away from
anarchy, and if you could attack a
society through its computers to cause
the breakdown of the mechanisms, the
infrastructure, which cause it to run,
you will bring about mass deaths.’
Line of sight devices. Two distinct
classes of line-of-sight devices have
been described. The first is a form
of low-energy radio-frequency
(LERF) jammer, which can be

used to temporarily disrupt digital
electronic circuits at close range (of
the order of metres). Since any cable
or circuit component in an electronic
system is in principle an unintended
antenna, capable of both transmitting
and receiving at its characteristic
frequency, a low-energy wide
spectrum RF field will contain with
high probability frequencies matching
the resonant frequencies of critical
circuit components.
If this is the case then the system
would go into ‘random output mode’;
its behaviour would be impossible to
predict, but could range from single
recoverable processing error to total
loss of the RAM contents. A parts
list and circuit design for such a low-
tech device was posted on an Internet
bulletin board in 1995 and described at
InfoWarCon in 1996. The device was
subsequently built and tested in the
UK to check the veracity of its design.
The second class of device is the
high-energy radio-frequency (HERF)
gun or non-nuclear electromagnetic
pulse (NN-EMP) cannon, which can
permanently damage digital circuits
at longer ranges (or the order of a
kilometre) by blasting them with a
pulse of microwave energy in the
Gigahertz frequency range. The
MOS chips are effectively ‘fried’ by
this process. HERF technology is
high-tech and remains the subject of
classified military research.
However, the unclassified technology
had been reviewed and discussed in
detail. In order to protect (or ‘harden’)
systems against RF attack they need to
be entirely enclosed in a Faraday cage,
ideally including the electrical power
feeds and communications links, since
these can act as antennas for the RF
field or EM transients.
Eavesdropping and surveillance.
Since a cable or circuit component
can act as a transmitting antenna,
unshielded computers and networks
are liable to leak compromising RF
emanations that are a potential source
of intelligence. Passive intelligence
gathering from unshielded systems
(ElInt) has been given the name
TEMPEST (transient electromagnetic
pulse emanation standard, see
Reference 16, note 3) while
emanations specifically arising from
the CRT screens of VDUs are known
as van Eck radiation after the scientist
who was able to demonstrate remote
reconstruction of the screen contents
using low-tech equipment.
It has been pointed out that malicious
software could be used to infiltrate
a target system, obtain critical
information, and encode it in the
system’s Tempest emanations in order
to broadcast it back to the attacker.
Summary and prospects. The threats
to, vulnerabilities of, and impacts on
critical national infrastructures (CNI)
are real and capable of assessment,
although in practice this is a complex
and challenging task, the more so
since information warfare possesses
several characteristics of that are not
shared by conventional warfare: it
is global (there are no borders); it is
precise (surgical strikes are possible); it
is un-proportionate (the cost of attack
is much less than the cost of defence).
Some of the accounts of information
warfare carried by the media have
been exaggerated or are inaccurate,
but this must not deflect us from
addressing the crucial issues of
defining, developing, and deploying
critical infrastructure protection (CIP)
policies and strategies.
(Extracted from “Information Warfare:
battles in cyberspace”, by Richard E
Overill, IEE Computing and Control
Engineering Journal, June 2001, pp125 –
128, www.theiet.org. There was a lot
about hackers and such, which has been
omitted from this extract.)
146
Case #22804: Lead boxes –
Good for Kryptonite, bad
for CRT monitors
A prestigious New York Hotel had
upgraded their check-in and reservation
JANUARY 2019 IN COMPLIANCE | 25
computers to modern PCs with colour
CRT monitors. One unit’s screen,
in the managers office, was nearly
impossible to read due to a wavy
image. Magnetic fields at up to 60
milligauss were found at the monitor
location and were coming from a power
company electrical vault under the
sidewalk outside. Some monitors can be
disturbed by as little as 10 milligauss.
Due to some bad advice, the hotel
had an aluminium box built (didn’t
work), then a lead box (didn’t work
either but at least now the monitor
was protected from Superman’s X-ray
vision). Eventually they came to us and
our standard five-sided ‘ImageGuard’
CRT monitor enclosure did the trick.
(From the Journal of Magnetic Shield
Case Studies, an in-house advertising
medium published by the Magnetic Shield
Corporation, www.magnetic-shield.com.)
The regular “Banana Skins” column was
published in the EMC Journal, starting
in January 1998. Alan E. Hutley, a
prominent member of the electronics
community, distinguished publisher of the
EMC Journal, founder of the EMCIA
EMC Industry Association and the
EMCUK Exhibition & Conference,
has graciously given his permission for
In Compliance to republish this reader-
favorite column.
The Banana Skin columns were compiled
by Keith Armstrong, of Cherry Clough
Consultants Ltd, from items he found
in various publications, and anecdotes
and links sent in by the many fans
of the column. All of the EMC Journal
columns are available at:
https://www.emcstandards.co.uk/
emi-stories, indexed both by application
and type of EM disturbance, and new ones
have recently begun being added. Keith has
also given his permission for these stories
to be shared through In Compliance as a
service to the worldwide EMC community.
We are proud to carry on the tradition
of sharing Banana Skins for the
purpose of promoting education for
EMI/EMC engineers.
26 | Feature Article
CONTINUING YOUR
PROFESSIONAL EDUCATION IN 2019
T
raditionally, the start of a
new year is a time when
we reflect on the progress
we’ve made during the year passed
and set our goals for the new
year. More often than not, your
professional development goals
include training or some form of
continuing education to expand or
refresh your technical knowledge.
We’ve queried training resources
in our industry to provide you
with an overview of free or
affordable solutions to meet your
training goals in 2019. You’ll find
here sources of compliance-
related seminars, workshops
and other types of training,
offered online and on location,
public and private.
Please note that all listings are
current as of the date we go to
press (early December 2018).
We invite you to submit updates
and corrections, as well as
suggestions for additional
listings for our events section.
Send your comments to us at
editor@incompliancemag.com.
PUBLIC SEMINARS AND
WORKSHOPS
The American Association
for Laboratory Accreditation
(A2LA) provides a variety
of courses designed to help
organizations achieve and
maintain accreditation to
international standards.
Instructors are subject matter
experts with many years of
professional training experience.
Most courses are offered at
several locations on various dates
throughout the year. Additional

Compiled by the In Compliance Magazine Staff
details are available at http://www.a2la.org/training.
(Also see listings under “In-House/Custom Seminars”
and “Webinars and On-Demand Training.”)
AEMC Instruments offers its “Understanding
Ground Resistance Testing” training seminar. This
one-day technical training seminar will provide you
with all the information you need to understand and
apply proper sizing and testing of grounding systems.
For additional details regarding its 2019 workshop
schedule, go to https://www.aemc.com/support/
training-seminars.cfm.
Keith Armstrong of Cherry Clough Consultants
will offer his two-day course on “Good EMC
JANUARY 2019 IN COMPLIANCE | 27
Engineering Practices for Large Machines, Systems
and Installations” on February 21-22, 2019 in Bruges,
Belgium. For more information, or to register, go to
https://iiw.kuleuven.be/brugge/m-group/Events/
EMCforSystemsandInstallations2019. (Also see
listing under “In-House/Customer Seminars” and
“Webinars and On-Demand Training.”)
Dangelmayer Associates is once again hosting its
annual ESD workshop, “ESD Best Practices for
Changing Technologies.” The workshop will be held
July 23-26 at the company’s headquarters in beautiful
Gloucester, Massachusetts (U.S.) Additional details
and registration information is available at
http://www.dangelmayer.com/training-workshops.php.
Doug Smith of D.C. Smith Consultants will offer
his seminar on “Lab Techniques, Robust Design, and
Troubleshooting” February 19-21, 2019 in Boulder
City, Nevada (U.S.). For more information, or to
register, go to http://emcesd.com/bcsem_hfmeas.htm.
Doug also continues to host the ever-popular EMC
Week in Boulder City, Nevada (U.S.), dedicated to
helping you learn everything you need to know about
EMC design and testing. This year’s event will be held
February 4-February 8, and will also feature Derek
Walton (“A Day in the EMC Lab.”), Dan Beeker (“PC
Board Design for EMC Compliance.”) and Ken Wyatt
(“EMC Troubleshooting & Compliance Testing at
Your Facility.”). Find additional details for EMC Week
at http://emcesd.com/bcsem_emcweek.htm.
Equipment Reliability Institute offers several public
courses throughout the year, including courses on
“MIL-STD 810G Testing and Fundamentals of
Random Vibration and Shock Testing.” For complete
information and 2019 training dates, go to
https://equipment-reliability.com/upcoming-training.
(Also see listing under “In-House/Custom Seminars.”)
28 | Feature Article
The ESD Association holds educational
opportunities throughout the year to provide
engineers with the knowledge and tools needed to
meet the challenges of ESD in their companies.
For example, the association co-sponsors regional
tutorials with local chapters, conducts a national
tutorial and education seminar in conjunction with
the annual EOS/ESD Symposium, and publishes and
distributes numerous educational materials on ESD.
For full details, visit the ESD Association’s website
at http://www.esda.org. (Also see listing under
“Webinars and On-Demand Training.”)
ETS-Lindgren offers hands-on training courses
throughout the year in Cedar Park, Texas (U.S.).
Courses planned for 2019 include:
• EMC Fundamentals
• Automotive EMC Testing
• TILE! Software Basic Training
• OTA Testing
• HEMP/EMI Threats
• EMC & MIL STD 461 Fundamentals
For information about specific course dates and other
course details, go to http://www.ets-lindgren.com/
services/education-training. (Also see listing under
“Webinars and On-Demand Training.”)
Daryl Gerke of Kimmel Gerke Associates, Ltd.
will conduct his three-day class on “EMC in
Military Systems” on February 5-7, 2019 at Applied
Technology Institute in Columbia, Maryland (U.S.)
For more information, or to register, go to
https://www.aticourses.com/EMI_EMC_in_
Military_Systems.htm. (Also see listing under
“In-House/Customer Seminars.”)
Intertek offers live seminars and workshops
throughout the year at various locations around
the U.S. and elsewhere. Additional information is
available at the “Intertek Electrical” Showcase page
on LinkedIn at https://www.linkedin.com/showcase/
intertek-electrical.
Dr. Todd Hubing of Learn EMC will present his
course on “Design for Automotive EMC Compliance”
in Santa Clara, California (U.S.) on February 5-7. The
course focuses on fundamental concepts and tools that
automotive electronics engineers can utilize to avoid
electromagnetic compatibility and signal integrity
problems. For additional details on this and other
courses, go to https://learnemc.com.
Mark Montrose of Montrose Compliance Services
will once again teach his course on “Printed Circuit
Board Design for Signal Integrity and EMC
Compliance” at the University of California Santa
Cruz Extension in 2019. Find details and updated
information at http://montrosecompliance.com/
training-seminars/seminars_courses. (Also see listing
under “In-House/Custom Seminars.”)
Silent Solutions offers workshops for design
engineers interested in a practical, hands-on approach
to EMC design, troubleshooting, and the special
field concerned with circuit-to-circuit interference.
Engineers working for manufacturers whose products
target commercial and industrial environments will
find this training extraordinarily useful. Visit
http://www.silent-solutions.com to learn more. (Also
see listing under “In-House/Custom Seminars.”)
TÜV SÜD America offers public training courses are
enhanced by the real-life experiences of the auditing
and testing teams, offering years of experience in
the worldwide international standards arena. These
courses can help prepare you for the most challenging
compliance issues. Visit their website at
http://www.tuv-sud-america.com/us-en/resource-
center/training. to see the current offerings. (Also see
listing under “Webinars and On-Demand Training.”)
UL Knowledge Solutions offers courses, workshops
and other forms of live training in the U.S. and in other
locations around the world. The world’s most progressive
and safety-conscious companies rely on UL’s educational
programs for the expertise and tools required to design
and install safer products, increase efficiency, realize
improved speed to market, and ultimately advance their
approach to prevention and compliance. A complete
listing of 2019 dates and locations is available at
https://lms.ulknowledgeservices.com/home.aspx. (Also
see listings under “In-House/Custom Seminars” and
“Webinars and On-Demand Training.”)
Washington Laboratories Academy will offer a wide
range of courses and workshops in 2019, including
their popular trainings on EMC essentials, EMC
PCB design and integration, and MIL-STD-461.
To learn more, visit the Washington Laboratories
 JANUARY 2019 IN COMPLIANCE | 29

Academy at http://www.wll.com/academy. (Also see

listings under “Webinars and On-Demand Training.”)

York EMC Services offers classroom compliance

training throughout the year at various locations
in the United Kingdom. To find out more visit
http://www.yorkemc.com/services/training.
(Also see listings under “In-House/Custom Seminars”
and “Webinars and On-Demand Training.”)

IN-HOUSE/CUSTOM SEMINARS
Many experts and training organizations offer standard
and/or customized seminars and workshops on an in-
house basis. These training programs offer companies an
opportunity to train multiple compliance personnel with a
specialized approach designed for their needs. Following
is a list of trainers and organizations that offer in-house
seminars and workshops.

The American Association for Laboratory

Accreditation (A2LA) also offers custom and on-site
courses available on a variety of topics. Go to
http://www.a2la.org/training for more information.
(Also see listings under “Public Seminars and
Workshops” and “Webinars and On-Demand Training.”)

Vladimir Kraz of Best ESD Technical Services offers

in-house classes on practical aspects of dealing with
EMI, EOS and ESD in real-life situations, such as
manufacturing, motion control, field installations and
alike, and how to reduce unwanted electrical noise in a
practical and effective way. For additional information,
go to http://www.bestesd.com.

Keith Armstrong of Cherry Clough Consultants also

offers an array of private, in-house seminars that can
facilitate a customized approach to training. Seminars
available for in-house delivery include:
• Electronic and mechanical design
• Electrical assembly and wiring
• EMC for functional safety
• Testing & standards for designers
• Testing & standards for testers

Go to https://www.cherryclough.com/Custom-Training-
Courses for more information. (Also see listing under
“Public Seminars and Workshops” and “Webinars and
On-Demand Training.”)
30 | Feature Article
Equipment Reliability Institute also provides on-site
training on a broad range of testing and design topics.
For more information, go to http://www.equipment-
reliability.com/onsite-courses. (Also see listing under
“Public Seminars and Workshops.”)
Daryl Gerke of Kimmel Gerke Associates, Ltd. also
offers his two-day course on “Design for EMC” on an
in-house basis. The course focuses on EMC problems
and how to identify, prevent and fix more than 40
common EMI/EMC problems at the equipment level.
For further details, visit http://www.emiguru.com/
seminars/emc-seminars. (Also see listing under “Public
Seminars and Workshops.”)
Mark Montrose of Montrose Compliance Services
also offers customized, in-house training programs
and workshop on achieving EMC compliance, and
EMC design fundamentals and techniques. For more
information, go to https://montrosecompliance.com/
emc-training-seminars/seminars_courses. (Also see
listing under “Public Seminars and Workshops.”)
Silent Solutions (http://www.silent-solutions.com)
offers many of its public seminars and workshops for
private, in-house delivery, and can also customize its
offerings to address specific organizational needs and
requirements. (Also see listing under “Public Seminars
and Workshops.”)
UL Knowledge Solutions also offers companies the
option of private and custom workshops designed and
delivered by UL subject matter experts. Learn more
at https://lms.ulknowledgeservices.com/common/
ncsresponse.aspx?rendertext=PrivateWorkshop.
(Also see listings under “Public Seminars and
Workshops” and “Webinars and On-Demand
Training.”)
Wyatt Technical Services, LLC An independent
consulting firm that specializes in EMC design,
troubleshooting and training services to commercial
and industrial manufacturers with global
distribution in the consumer, computer, network and
telecommunications, industrial and scientific industries.
Also participating in the 2019 EMC Week in Boulder
City, NV (U.S.). For further information, visit
http://www.emc-seminars.com/page6/Schedule.html.
(Also see listing under “Webinars and On-Demand
Training.”)
York EMC Services also offers customized, in-house
training offerings in addition to their comprehensive
schedule of public training programs. For additional
details on their ‘bespoke” training options, go to
https://www.yorkemc.com/services/training/bespoke-
training. (Also see listings under “Public Seminars
and Workshops” and “Webinars and On-Demand
Training.”)
WEBINARS AND ON-DEMAND TRAINING
Since you can’t be on the road all the time, there
is plenty of training that you can participate in
right from your desk. Many experts and training
organizations provide live and on-demand webinars,
as well as books, podcasts, and e-learning programs.
Here are a few options to get you started:
The American Council of Independent Laboratories
(ACIL) will continue to host its webinar series
covering a wide variety of EMC standards, key EMC
committee meetings and other EMC activity. The
webinars will be presented by Don Heirman. Dates
and time for scheduled webinars is available at the
ACIL website at http://www.acil.org. The website also
provides information on previously recorded webinars
that are available on-demand.
The American Association for Laboratory
Accreditation (A2LA) In addition to its public
workshops (see previous listings), the A2LA also
offers a number of online training options, including
webinars and videos. Go to http://www.a2la.org/
training for further details. (Also see listings under

“Public Seminars and Workshops” and “In-House/
Custom Seminars.”)
Associated Research webinars are available both live
and on-demand, and provide detailed information
on many aspects of electrical safety testing. For more
information, go to http://www.arisafety.com/webinars.
Keith Armstrong of Cherry Clough Consultants
has uploaded recordings of many of his webinars on a
variety of EMC-related issues to the EMC Standards
portal. Visit https://www.emcstandards.co.uk/
overview-of-the-basic-test-methods-for-emc-dire for
additional details. (Also see listing under “In-House/
Customer Seminars” and “Webinars and On-Demand
Training.”)
EMC Fast Pass provides comprehensive on-line
training courses and short courses to assist electronic
engineers, compliance specialists and hardware
JANUARY 2019 IN COMPLIANCE | 31
manufacturers design and test products that pass
EMC and RF certifications the first time. Some of
their course offerings include:
Comprehensive Programs
• EMC Design for Compliance
• Intrinsically Safe Hardware Design
• EMC Troubleshooting and Pre-Compliance Testing
Short Courses
• EMC Testing Beginner’s Bundle
• FCC Wireless (RF) Pre-Compliance
• Antenna Matching
• EMC Design Review Case Study
Visit https://emcfastpass.com/training/index.php/
course-listings for more information.
From components and devices to chambers and testing services,
the In Compliance Directory has you covered.

https://incompliance-directory.com
Find the solutions provider that is right for you

ESD Association, in addition to its public seminars
and workshops, also hosts online classes and training
videos through the ESDA Online Academy at
http://www.esda.org/training-and-education. (Also
see listings under “Public Seminars and Workshops.”)
ETS-Lindgren will also be presenting a number of
webcasts in 2019. Additional details are available at
http://www.ets-lindgren.com/services/education-
training. (Also see listing under “Public Seminars and
Workshops.”)
SIEMIC presents a series of monthly, one-hour
regulatory compliance webinars throughout the year
that address the latest regulation changes, importation
requirements, and hot compliance issues for the most
important and dynamic market countries. Go to
http://www.siemic.com/us/company/webinars.php for
additional information.
TÜV SÜD America also offers both live and on-
demand webinars covering various topics in the areas
of product safety, EMC, management systems and
competency assessments. To learn more, go to
https://www.tuv-sud-america.com/us-en/resource-
center/training/webinars. (Also see listing under
“Public Seminars and Workshops.”)
UL Knowledge Solutions also provides safety- and
compliance-related training delivered via self-paced
online training, webinars, and more. UL’s Regulatory
and Compliance Essentials offering is a continuously-
growing portfolio of online courses spanning across a
wide spectrum of topic areas including hazard-based
safety engineering, global market access and global
directives, code compliance, conformity assessment,
sustainability, responsible sourcing and social
auditing, and many more. For additional details, visit
https://lms.ulknowledgeservices.com/Common/
NCSResponse.aspx?RenderText=fundamentals_
subscriptions. (Also see listings under “Public Seminars
and Workshops” and “In-House/Custom Seminars.”)
Washington Laboratories Academy also offers a
comprehensive line-up of live and on-demand webinars
on a variety of compliance-related issues. For more
information, go to http://www.wll.com/academy. (Also
see listing under “Public Seminars and Workshops.”)
JANUARY 2019 IN COMPLIANCE | 33
Wyatt Technical Services also offers its on-line course,
EMC Troubleshooting and Pre-Compliance Testing for
Product Designers, which covers the basics of EMC
design and how to correct typical design issues, simple
pre-compliance bench top measurement methods,
and simple techniques and tools to characterize
designs at various stages of development. Go to
http://www.emc-seminars.com/page6/Schedule.html
for more information. (Also see listing under
“In-House/Custom Seminars.”)
York EMC Services offers a number of online
training course modules through its York Training
Academy. Current titles include:
• Introduction to EMC Standards
• Implications of the New EMC Directive
• Ensuring the Continued Compliance of Products
with the EMC Directive
More details are available at https://www.yorkemc.com/
services/training/online-training. (Also see listings
under “Public Seminars and Workshops” and
“In-House/Custom Seminars.”)
INDUSTRY SYMPOSIA, CONFERENCES
AND EXHIBITS
These annual symposia are an excellent resource
for extensive technical training, and exchange of
new ideas and technical concepts. The benefit of
attending these events is that attendees can sample a
vast array of workshops quickly and efficiently while
networking with colleagues and professionals with the
same interests.
DesignCon 2019
January 29-31, 2019 – Santa Clara, California (U.S.)
https://designcon.com
EMV 2019
March 19-21, 2019 – Stuttgart, Germany
https://emv.mesago.com/events/en.html
Microwave & RF 2019
March 20-21, 2019 – Paris, France
http://www.microwave-rf.com
34 | Feature Article
2019 International Electrostatic Discharge
Workshop (IEW)
March 31-April 4, 2019 – Monterey, California (U.S.)
https://www.esda.org/events/iew
EuCAP 2019 – The 13th European Conference on
Antennas and Propagation
March 31-April 5, 2019 – Krakow, Poland
http://www.eucap2019.org
2019 International Applied Computational
Electromagnetics Society Symposium
April 14-18, 2019 – Miami, Florida (U.S.)
http://www.aces-society.org/conference/Miami_2019
2019 IEEE Symposium on
Product Compliance Engineering
May 6-8, 2019 – San Jose, California (U.S.)
http://psessymposium.org
2019 IEEE International Instrumentation and
Measurement Technology Conference (I 2MTC)
May 20-23, 2019 – Auckland, New Zealand
http://imtc.ieee-ims.org
2019 Asia-Pacific International Symposium on
Electromagnetic Compatibility
June 3-7, 2019 – Sapporo, Hokkaido, Japan
http://www.ieice.org/~emc2019
IMS2019 – 2019 International Microwave Symposium
June 2-7, 2019 – Boston, Massachusetts (U.S.)
http://www.ims2019.org
2019 IEEE International Symposium on
Electromagnetic Compatibility,
Signal and Power Integrity
July 22-26, 2019 – New Orleans, Louisiana (U.S.)
https://www.emc2019.emcss.org
EMC Europe 2019
September 2-6, 2019 – Barcelona, Spain
https://emceurope2019.eu
2019 Electrical Overstress/Electrostatic
Discharge Symposium
September 11–20, 2019 – Riverside, California (U.S.)
https://www.esda.org/events/symposia
European Microwave Week 2019
September 29-October 4, 2019 – Paris, Spain
http://www.eumweek.com
41st Annual Symposium of the Antenna
Measurement Techniques Association (AMTA)
October 6-11, 2019 – San Diego, California (U.S.)
https://amta2019.org
IEEE EMC SOCIETY 2019 REGIONAL EVENTS
Milwaukee EMC Society will once again host their
annual EMC Event in Milwaukee, Wisconsin (U.S.)
in March-April 2019. For up-to-date information on
this event go to http://www.EMCMilwaukee.com.
2019 Chicago IEEE EMC Mini Symposium
May 4, 2019—Chicago, Illinois (U.S.)
http://www.emcchicago.org/sectfiles/events.htm
EMC Fest 2019
May 9, 2019 – Livonia, Michigan (U.S.)
http://www.emcsociety.org/wp/?page_id=35
2019 Minnesota EMC Event
September 19, 2019 – Bloomington, Minnesota (U.S.)
http://www.mnemcevent.com
8th Annual EMC Seminar
IEEE Rock River Valley Section, Northern Illinois
and Southern Wisconsin
June 11, 2019—Rockford, Illinois (U.S.)
http://www.ieee.org/rrvs
We hope this list will help you meet your professional
development goals in 2019. Many additional events will
be planned throughout the year, so, to find the most
up-to-date information, be sure to check our events
calendar at https://incompliancemag.com/events.
Another way to brush up on the basics and delve
deep into advanced topics is by visiting our online
resource center, the In Compliance Electrical
Engineering Resource Center (EERC) at
http://incompliancemag.com/eerc.
36 | Feature Article

BREXIT AND ITS IMPACT

ON MARKET ACCESS
Considerations for Placing Products on the European Market after 30 March 2019
 JANUARY 2019 IN COMPLIANCE | 37

Dr. Susanne Wende, LL.M., is an attorney at Noerr LLP, and specializes in

European Product Compliance and Product Liability Law. She advises and
represents clients in their dealings with market surveillance authorities across
Europe as well as with regard to product liability issues. She lectures on product
liability law at the Technical University of Berlin and regularly speaks on different
aspects of European product compliance at conferences and in webinars and in-
house training courses. She can be reached at Susanne.Wende@noerr.com.

By Susanne Wende

O
n 29 March 2017, the United Kingdom (UK)
submitted notification of its intention to
withdraw from the European Union (EU). As
the EU is now far more than merely a supranational
economic institution, the actual withdrawal, which
will take place automatically on 30 March 2019, 0:00
CET, will have a variety of consequences for economic
operators acting in the European market. Many
voices in legal literature see Brexit as a mammoth task
which will keep several generations of lawyers busy.1
Manufacturers placing their products on the European
market will be affected by the elimination of the
free movement of goods as one of the fundamental
freedoms in the EU.
The following article will provide an analysis of what
steps should be taken now in order to be prepared. The
article is based on the current status (as of the end of
November 2018) of withdrawal negotiations between
the EU and the UK with regard to the free movement
of goods.
PLACING PRODUCTS ON THE EUROPEAN
MARKET UNDER THE FREE MOVEMENT
OF GOODS
European Product Law
According to the current legal framework in Europe,
a product once placed legally on a market of an EU
Member State may be circulated freely throughout
the European Economic Area (EEA, which includes
the EU Member States, Norway, Liechtenstein
and Iceland). There are European Directives and
Regulations for a variety of products. With regard
to electronic products, these include the EU Low
Voltage Directive (2014/35/EU), the Electromagnetic
Compatibility Directive (2014/30/EU), the Radio
Equipment Directive (2014/53/EU), the RoHS
Directive (2011/65/EU), and the specific legal
framework on ecodesign and energy consumption
labeling based on Directives 2009/125/EC and
2010/30/EU.
With the exception of Directive 2010/30/EU, each
of these legal acts is subject to the same principles
of European product compliance law, mainly the
common legal framework based on the CE marking
as a manufacturer’s declaration of conformity
and the presumption of conformity granted if
a product complies with the relevant European
harmonized standards. The common legal framework
defines various economic operators, including the
manufacturer that designed and produced the product
or had it designed and produced, regardless of whether
that manufacturer is based in or outside the EU.
The legal framework also defines the importer of
a product, which is any natural or legal person
established within the EU that places a product from
a third country on the EU market. There is always an
importer if a product was produced by a manufacturer
not based in the EU. The importer is the person who
will be contacted and held responsible for product
compliance by the national market surveillance
authorities enforcing European product compliance
law. A manufacturer may also designate an authorized
representative by written mandate. The authorized
representative is then fully responsible for product
compliance. In such cases, the EU importer has a less
important role.
There are very few EU legal acts on product
compliance in which an authorized representative is
mandatory for a manufacturer based outside the EU.
For example, the European Directive on Medical
Devices (93/42/EEC), which will be replaced in
2020 by Regulation (EU) 2017/745, requires a sole
authorized representative if the manufacturer is not
based in the EU.
38 | Feature Article
Brexit will have an influence on the core principles of
European product compliance, even if products are placed
on the market in European countries other than the UK.
Another economic operator subject to European
product compliance law is the distributor.
“Distributor” means any natural or legal person in
the supply chain, other than the manufacturer or the
importer, who makes the product available on the
market. The distributor has its own obligations with
regard to the product made available on the market,
mainly monitoring obligations.
A core element of European product law is the
CE marking. The manufacturer or its authorized
representative attach the CE marking to the product
and thereby declare it compliant with all applicable legal
requirements. A product with a CE marking may freely
circulate between the different EU Member States.
The affixing of the CE marking is the last step in a
complex procedure of conformity assessment provided
for in the legal acts. The applicable conformity
assessment procedures are laid down in specific
legal acts applicable to a given product. They consist
of different modules, some of which require the
intervention of a third party known as a Notified
Body. Notified Bodies are accredited in accordance
with a specific procedure laid down by law. Due
to their enhanced scientific knowledge, market
surveillance authorities are obliged by law to take
particular account of the technical assessment of a
Notified Body.
Other Legal Frameworks for Product Circulation
in Europe
Brexit will have an influence on the core principles
of European product compliance, even if products
are placed on the market in European countries
other than the UK. In order to present the possible
Brexit scenarios in a comprehensible way, the
following sections will describe the existing forms of
approximation to the free movement of goods with
third countries.
EEA Agreement
Norway, Iceland and Liechtenstein are fully subject
to the free movement of goods even though they are
not EU Member States. They entered into a specific
agreement with the EU and its Member States within
the European Economic Area (EEA). As a result, all
European product legislation also applies to the EEA
countries. The objective of the EEA Agreement is to
establish a dynamic and homogeneous geographical
area throughout Europe in which common rules and
equal conditions of competition apply.
Rights conferred and obligations imposed upon
the EU Member States, or their public entities,
undertakings, or individuals in relation to each other,
are also understood to be conferred or imposed in
the same way upon the EEA States. This ensures
that the EEA States, and their economic operators,
are subject to the same rights and obligations as
their counterparts in the EU. For instance, the New
Approach directives and other EU harmonization
legislation are implemented and applied in exactly
the same way in the EEA States as in EU Member
States. For the purpose of references within the EEA
Agreement to the EU or the single market in the
EU/EEA, acts are understood to include the
territories of the Contracting Parties. Accordingly, a
product is not only placed on the Union market, but
on the EEA market as well (i.e., the national markets
of the Member States and Iceland, Liechtenstein
and Norway).
The EEA Agreement is amended on a continuous
basis through decisions of the EEA Joint Committee
to help ensure continued consistency with relevant
Union legislation. To arrive at and maintain
the uniform interpretation and application of
the Agreement, an EFTA Court and an EFTA
Surveillance Authority have been established.

Industries which are not covered by EU product legislation
are still granted free movement of goods within the EU by
the principle of mutual recognition.
The EEA Agreement ensures close cooperation
between the European Commission and the
administration of the EEA States. The Commission
seeks informal advice from experts of these States
in the same way as it seeks advice from experts of
the Member States. Close cooperation has also
been established between committees assisting
the Commission in its work. The EEA Joint
Parliamentary Committee and the EEA Consultative
Committee conduct regular meetings, while the EEA
Council meets biannually.
Bilateral Agreements on Customs Union or Mutual
Recognition
There are countries in which the free movement
of goods, or parts thereof, is governed by bilateral
agreements with the EU.
Turkey and the EU established a Customs Union in
1995 (Decision 1/95 of the EU-Turkey Association
Council, 96/142/EC). The Customs Union Decision
covers trade between Turkey and the EU in
manufactured products and processed agricultural
products, and entails alignment of Turkey with all
EU product legislation. The Agreement aims to
ensure the free movement of manufactured products
and processed agricultural products between the EU
and Turkey by eliminating import controls on such
products at the EU-Turkey border. Articles 5 to 7 of
the Decision provide for the elimination of measures
having an effect equivalent to customs duties between
the EU and Turkey, mirroring Articles 34-36 TFEU.
As a consequence, in the sectors for which Turkey has
aligned its legislation with that of the EU, a product
lawfully manufactured and/or marketed in Turkey
should be treated as equivalent to a product lawfully
manufactured and/or marketed in the EU and should
not be subject to import controls.
The Mutual Recognition Agreement (MRA)
concluded with Switzerland is a comprehensive
JANUARY 2019 IN COMPLIANCE | 39
agreement based on the equivalence of the legislation
of the EU and Switzerland. It covers the recognition
of conformity assessments irrespective of the origin
of the products except for specific product categories
such as medical products. The case of Switzerland is
quite unique. The provisions of the Agreement and
the harmonization of Swiss technical regulations with
those of the EU ensure free market access for EU
products to the Swiss market, and for Swiss products
to the EU/EEA market.
There is, however, no customs union between the EU
and Switzerland. According to the Agreement, the
Swiss Accreditation Service (SAS) is a full member of
European cooperation for Accreditation (EA). In the
area of standardization, Switzerland is a full member
of a variety of European standardization bodies
and participates actively in the work of European
standardization. Furthermore, the conformity
assessment bodies of the EU Member States and of
Switzerland are allowed to issue certificates which are
deemed equivalent to each other. This is only possible
because, firstly, Switzerland has an existing technical
infrastructure which is equally developed and deemed
equivalent to the EU’s. 2 Secondly, Switzerland
has chosen to modify its legislation in the sectors
covered by the agreement in order to align it with
that of the Union. Most notably, it has committed to
actively maintaining legislative alignment whenever
amendments are introduced by the Union to the
applicable EU legal framework.
Principal of Mutual Recognition within the EEA
Industries which are not covered by EU product
legislation are still granted free movement of goods
within the EU by the principle of mutual recognition.
National technical regulations are subject to the
provisions of Articles 34 to 36 of the Treaty on the
Functioning of the European Union (TFEU), which
prohibit quantitative restrictions or measures having
equivalent effect. The case law of the European
40 | Feature Article
Because of uncertainties about the timely conclusion of a
withdrawal agreement, companies clearly need to further
develop their contingency plans for a hard Brexit.
Court of Justice, especially the “Cassis de Dijon” case
provides the key elements for mutual recognition.
According to this case law, products lawfully
manufactured or marketed in one EEA Member
State should in principle move freely throughout the
EEA where such products have equivalent levels of
protection to those imposed by the EEA Member
State of destination. Barriers to free movement which
result from differences in national legislation may only
be accepted if national measures are: 1) necessary to
satisfy mandatory requirements (such as health, safety,
consumer protection and environmental protection);
2) serve a legitimate purpose which justifies overriding
the principle of free movement of goods; and 3) are
proportionate with the aims.
CURRENT STATE OF WITHDRAWAL
NEGOTIATIONS:
WHAT WILL HAPPEN ON 30 MARCH 2019?
The newspapers have been full of articles detailing the
state of negotiations between EU Chief Negotiator
Michel Barnier and the UK government. As of this
writing (end of November 2018), the UK cabinet and
the EU-27 Member States have agreed to back the
current draft withdrawal agreement, but agreement of
the British House of Commons would still be required.
Furthermore, it appeared that many Members of the
British Parliament do not agree with the withdrawal
agreement, chiefly because of the United Kingdom
would remain part of the Customs Union.
Because of these and other uncertainties about
the timely conclusion of a withdrawal agreement,
companies clearly need to further develop their
contingency plans for a hard Brexit, under each of the
following three possible scenarios:
Scenario 1: No Deal
On 30 March 2019, 0:00 CET, the UK will
automatically withdraw from the EU and all primary
and secondary EU law will cease to apply unless a
ratified withdrawal agreement establishes another date.
This legal consequence is ordered by Art. 50(3) Treaty
on the European Union (TEU) which reads as follows:
“The Treaties shall cease to apply to the State in
question from the date of entry into force of the
withdrawal agreement or, failing that, two years after
the notification referred to in paragraph 2, unless the
European Council, in agreement with the Member State
concerned, unanimously decides to extend this period.”
According to the opinion of the European
Commission, the UK will, from that moment on,
neither be a member of the European Economic Area
(EEA) nor the EFTA nor any other European trade
agreement. There are, however, some legal experts
who argue that the UK would remain a member of the
EEA even after its withdrawal from the EU because
the EEA is an international treaty with the EU
itself and with the individual EU Member States as
parties. Therefore, if there is no withdrawal agreement
established by 30 March 2019, some parties might
choose to initiate legal filings that would require a
clarifying judgment by the European Court of Justice.
Scenario 2: Current Draft Withdrawal Agreement
is Signed
If the current draft withdrawal agreement is signed
before 30 March 2019, there will be no change in law
for another 21 months. According to Art. 126 of the
draft withdrawal agreement, there will be a transition
period from 30 March 2019 until 31 December
2020. According to Art. 127 of the draft withdrawal
agreement, EU law would remain applicable to and
in the UK during the transition period. Accordingly,
even though the UK would no longer be a Member
State within the EU after 30 March 2019, product
compliance law and legal requirements with regard to
the free movement of goods would still be applicable
between the UK and the EU.

The UK government has pointed out that the establishment by
the UK and the EU of a free trade area for goods is the core
element of a proposal for the UK-EU economic partnership.
With regard to the cross-border distribution of
products, Art. 41 of the draft withdrawal agreement
provides that all products already placed on the market
in the UK or in an EU-27 Member State on the day
the transition period expires may continue to circulate
freely throughout the EU-28 area. The withdrawal
agreement contains no provisions on the trade
relationship between the UK and the EU-27 after the
end of the transition period. Moreover, this will be
subject to negotiations during the transition period.
Only the Protocol on Ireland/Northern Ireland, which
forms part of the withdrawal agreement, contains
in its Art. 8 provisions on technical regulations,
assessments, registrations, certificates, approvals and
authorizations. The provision states that EU product
compliance law shall be applicable to goods imported
to Northern Ireland from the EU. This provision
would be in force until a long-term agreement on
Ireland/Northern Ireland is reached.
Furthermore, there is a draft political notice which is
meant to be an annex to the withdrawal agreement.
However, the wording of this note is so general
that economic operators cannot know whether the
future trade relationship will be closer to the EEA
agreement with Liechtenstein, Norway and Iceland
or significantly less close – such as the bilateral
agreement with Switzerland. The UK originally
intended to agree on a bilateral agreement with
recognition of conformity assessment procedures,
notified bodies and omission of any custom controls
at the border. However, the UK did not want to be
obliged to implement all European product law, but to
have a choice on a case-to-case basis.
In a former statement, the UK government pointed
out that the establishment by the UK and the EU
of a free trade area for goods is the core element of a
proposal for the UK-EU economic partnership. 3 A
white paper prepared by the UK government provides
insight into their ideas: the UK has proposed the
JANUARY 2019 IN COMPLIANCE | 41
establishment of a free trade area for goods. According
to this proposal, the UK and the EU would maintain
a common rule book for goods, with the UK making
an upfront choice to commit by treaty to ongoing
harmonization with EU rules on goods, covering only
those necessary to provide for frictionless trade at
the border.4 At the same time, the UK proposal sets
out deep participation of the UK in EU agencies that
facilitate goods being placed on the EU market. It
acknowledges, however, that the UK would not have
any voting rights on the European standardization
bodies.5 The UK proposal also suggests that only one
procedure of conformity assessment in either market,
UK or EU-27, should be necessary in order to place
products on both markets.6
However, the EU Chief Negotiator and the European
Commission have stated quite clearly that they do not
agree with this approach as proposed since it would be
too biased in favor of the UK.
Scenario 3: Extension of Negotiation Period
According to Art. 50(3) TFEU, the UK and the
European Council may unanimously decide to extend
the period in which all EU law still applies to the UK.
While such a possibility was discussed as recently as
November, it is no longer mentioned in the course
of current developments. At the moment, forecasted
scenarios are limited to “deal” or “hard Brexit.”
POTENTIAL RAMIFICATIONS FOR U.S.
MANUFACTURERS
Against this background, U.S. manufacturers should
remain mindful of three potential legal effects, which
are detailed in the following sections.
UK as Country of Entry to the European Market
One of the major legal repercussions will affect
products from third countries which have already
entered the European market through the UK. As the
42 | Feature Article
An economic operator based in the UK will no longer be
accepted as an authorized representative by the European
Commission, since an authorized representative must be
based in the EU.
UK will be a third country from 30 March 2019, 0:00
CET, products entering UK Customs can no longer
be legally placed on the European single market. As
a consequence, the economic operator importing the
products to the UK will no longer be the EU importer.
Products that are transported from the UK to Ireland
or other European countries will only be imported in
the EU by this first transaction.
As a consequence, an economic operator established in
the EU-27 that was considered as an EU distributor
prior to the withdrawal date will become an importer
for the purposes of Union product legislation
applicable to the products they place on the EU
market and will have to comply with the specific
obligations relevant to an importer, which are different
from those of a distributor.
Consequences for the Choice of Authorized
Representatives
An economic operator based in the UK will no
longer be accepted as an authorized representative
by the European Commission, since an authorized
representative must be based in the EU. If the
manufacturer does not take any steps with regard to its
authorized representative, the following two scenarios
are likely.
Voluntary Authorized Representative
If the applicable product legislation gives a choice to the
manufacturer whether or not to appoint an authorized
representative, the product may still be legally placed
on the EU market. However, as there is no longer an
authorized representative, the first distributor in an
EU Member State will be viewed as an EU importer
and will be required to assume new and enhanced
responsibilities. Accordingly, the manufacturer and the
distributor should be prepared to address these potential
new responsibilities. As an alternative, the manufacturer
could find an authorized representative in another EU
Member State outside of the UK.
Mandatory Authorized Representative
If, however, the applicable product legislation contains
an obligation for the manufacturer based outside the
EU to involve an authorized representative (such as
the legislation on medical devices), the product can no
longer be legally placed on the European market by an
authorized representative based in the UK. Instead,
manufacturers will have to designate an EU-based
authorized representative in order to remain compliant
with EU legal requirements and to continue to legally
place products on the EU market.
Consequences for the Choice of Notified Bodies
In some product areas, EU legislation requires the
intervention of a Notified Body in the conformity
assessment procedure. EU product compliance law
requires Notified Bodies to be established in an
EU Member State and be designated by a national
accreditation body for performing the conformity
assessment tasks set out in the relevant EU legal act.
Therefore, as of the date of withdrawal from the EU,
Notified Bodies based in the UK will lose their EU
Notified Body status and will be removed from the
Commission’s information system (NANDO database).
The UK has suggested that all manufactured goods
authorizations, approvals, certifications and any
agency activity undertaken under EU law that are
completed prior to the end of the implementation
period continue to be recognized as valid in both the
EU and the UK. Furthermore, any such processes
underway as the UK and the EU transition during
the implementation period should be completed under
existing rules, with the outcomes respected in full.7
The European Commission makes quite clear in its
notice that it will not follow the suggested approach.
If there is no agreement reached on these and
other transitional provisions, U.S. manufacturers
will need to take timely action. Every product
placed on the European market that has to be

If a transition period is agreed upon between the parties,
the applicability of EU product law to the UK will ultimately
end at some point. Manufacturers should take steps now to
embrace the approaches discussed in this article.
assessed by a Notified Body in the course of its
conformity assessment procedure will require a
certificate issued by a recognized EU Notified Body
at the time that product is placed on the EU-27
market. In brief, this means that products assessed by
a UK Notified Body cannot be placed on the market
after 30 March 2019. This holds true even in cases in
which the Notified Body was fully authorized under
EU law to conduct such an assessment at the time the
assessment was performed.
As there is not yet an agreement on transitional rules,
economic operators are advised by the European
Commission to take the necessary steps to ensure
that where the applicable conformity assessment
procedures require the intervention of a Notified Body
they have certificates issued by an EU-27 Notified
Body to demonstrate compliance for their products
placed on the market as of the withdrawal date.
The European Commission suggests that economic
operators either apply for a new certificate from an
EU-27 Notified Body or arrange for a transfer of the
existing certificate to a new Notified Body in another
EU Member State.8
SUMMARY AND STEPS TO TAKE
Since representatives in both the UK and the EU
have expressed an interest in finding a solution that
will help to ensure a smooth transition, some think
it unlikely that there will be major legal changes to
placing products on the European market after 30
March 2019. However, if there is no agreement in
place by 30 March 2019, U.S. manufacturers will have
to be prepared for legal changes with regard to three
main aspects:
• UK as an import country to the EU
• Choice of Notified Bodies
• Choice of authorized representative
JANUARY 2019 IN COMPLIANCE | 43
And even if a transition period is agreed upon between
the parties, the applicability of EU product law to the
UK will ultimately end at some point. Accordingly,
manufacturers should take steps now to embrace the
approaches discussed in this article.
REFERENCES
1. Examples: Herrmann, EuZW 2017, 961 [967].
2. European Commission, Commission Notice -
The ‘Blue Guide’ on the implementation of EU
products rules 2016, OJ C272/121.
3. Statement from HM government, Chequers,
6 July 2018, p. 1, available at
https://assets.publishing.service.gov.uk/
government/uploads/system/uploads/
attachment_data/file/723460/CHEQUERS_
STATEMENT_-_FINAL.PDF.
4. United Kingdom, HM Government, The Future
Relationship between the United Kingdom and the
European Union, p. 15.
5. United Kingdom, HM Government, The Future
Relationship between the United Kingdom and the
European Union, p. 20.
6. United Kingdom, HM Government, The Future
Relationship between the United Kingdom and the
European Union, p. 20.
7. United Kingdom, HM Government, The Future
Relationship between the United Kingdom and the
European Union, p. 22.
8. European Commission, Notice to stakeholders –
Withdrawal of the United Kingdom and
EU Rules in the field of industrial products,
22 January 2018, p. 4.
44 | Feature Article

UPCOMING CHANGES TO UN 38.3

LITHIUM BATTERY TESTING
A Review of Amendment 1 to the 6th Revised Edition
 JANUARY 2019 IN COMPLIANCE | 45

John C. Copeland is co-owner and technical manager for Energy Assurance LLC,
an independent, fully-accredited cell and battery test laboratory. His career has
included various positions in quality engineering, reliability engineering, failure
analysis, project management, supplier assessment, and quality management in the
electronics and portable energy sectors. John holds a BSEE from Auburn University,
MSQA from Southern Polytechnic State University, and is trained as a Six-Sigma
Black Belt. He can be reached at johncopland@energy-assurance.com.

By John C. Copeland

T
he UN Recommendations on the Transport
of Dangerous Goods, Manual of Test and
Criteria outlines recommended testing
to minimize hazards that might occur during
transportation by air, ground or vessel. Section 38.3
deals specifically with the transportation testing
requirements for rechargeable and non-rechargeable
lithium cells and battery packs. This series of tests
is commonly known as “T1-T8” testing in reference
to the regime’s eight component tests. The current
version is the 6th Revised Edition which became
effective in January 2016.
Released in late 2017, Amendment 1 to the 6th revised
edition will become effective on January 1, 2019. The
scope of changes includes:
• Updates to the test scope and definitions;
• The addition of test tables to clarify the testing and
quantity of samples required;
• A major change in pre-conditioning cycling
requirements; and
• Standardization of test summary reporting
requirements.
The scope statement at the beginning of the standard
provides detail regarding which tests are required
for the many categories of lithium energy devices,
be they a cell or battery pack, rechargeable or non-
rechargeable, etc. An omission had previously been
noted regarding embedded batteries, that is, batteries
that are installed in the device that they power and
are never shipped outside of that device (an example
might be a portable power tool that has a built-in,
non-removeable battery). A statement that has been
appended to the scope notes that such batteries may
be tested while installed in their supported host
device. This is important as some batteries of this
type rely on the host device for both mechanical and
electrical protections, and thus testing them alone is
not representative of how they will be presented for
transportation.
The definition of the criteria term “Disassembly” was
also expanded. In general terms, disassembly refers
to the rupture of the cell or battery case where solid
materials are ejected, but this is further qualified to
mean that the energy must be low enough such that
the ejected materials do not penetrate a specified metal
screen placed around the device at a specific distance.
Amendment 1 permits alternative methods to the
metal screen if equivalence can be demonstrated.
Amendment 1 adds test tables for both non-
rechargeable (“Primary”) and rechargeable
(“Secondary”) devices. The table links the type of
device, the tests required, the quantity of samples,
and their respective charge state at the beginning of
testing. The intent of these tables is to better present
the user with a clearer explanation of the standard’s
requirements, thus reducing the chance of improper
application. An example of such a table is shown in
Figure 1 on page 46.
A critical change implemented by Amendment
1 is a 50 percent reduction in the number of
charge-discharge cycles required for preparation of
rechargeable cells and batteries. Previously, 50 cycles
were required. This has been reduced to 25 cycles, a
duration believed more efficient to age the products for
the purposes of this standard.
Finally, Amendment 1 implements the minimum
requirements for a standardized test summary report
(see Figure 2 on page 47). The intent is to ensure a
degree of consistency in the reporting of the testing
that might be reviewed by carriers, regulators
and other supply chain entities. Most of these
requirements were already being included by most test
46 | Feature Article
labs. They provide sufficient identification information
in addition to test results and are in keeping with
laboratory reporting requirements found in quality
systems such as ISO/IEC 17025.
The actual testing specified within the standard remains
virtually unchanged. For those seeking to achieve
compliance, this means ensuring the design of the
battery is both electrically and particularly mechanically
robust. As a commercial test lab specializing in cell
and battery testing, we see a significant volume of this
Figure 1: Test table for primary cells and batteries
testing and would offer that most test failures occur
during the T1-T5 sequence. The sequential aspect
refers to the fact that the same eight batteries will be
put through five stress tests in sequence. Half of these
units will be fresh, whereas the balance will have been
charge-discharge cycled 25 times to bring in an element
of aging. All tests are run with the units configured as
they will be during shipment.
Descriptions of the five sequential tests along with
typical failure concerns follow:

• T1: Altitude - This test simulates storage at 50,000
feet above sea level for six hours. The stress is
only that of vacuum, as it is conducted at room
temperature as opposed to the frigid reality of
high altitude. Failures during this testing are
exceptionally rare. Concerns include improperly
sealed pouch cells that may lose mass or battery
packs that may not withstand the difference in
pressure, causing a plastic housing part to pop off.
Again, these are very infrequent occurrences.
Figure 2: Test summary minimum reporting requirements
JANUARY 2019 IN COMPLIANCE | 47
• T2: Thermal - This test involves thermal cycling the
product between two temperature extremes, +72C
and -40C. Both are outside the typical storage
temperature range of most lithium cells. Failures
are not frequent but do occur. Most typical are
mass loss due to minor cell venting. Less frequent
are thermal fatigue failures to poor quality welds or
solder joints.
• T3: Vibration - Most failures happen during this
test. The vibration profile is very intense reaching
48 | Feature Article

For those new to needing to achieve compliance,

having a full understanding of what test parameters
will be applied to the design is critical. Additionally,
some degree of pre-testing, either in-house or
outsourced, may be beneficial to improve the
chances of a successful first-time outcome.

up to eight times the force of gravity at 200 Hertz.
Perhaps more significant is that the duration of
testing is a full nine hours, three hours in each of
three cardinal planes. The majority of failures occur
at the battery pack level and originate from internal
components (cells, circuit boards, etc.) coming loose
resulting in broken interconnects or other breakage.
• T4: Shock - This test is #2 in likelihood for test
non-compliances. This test involves the application
of 18 half-sine mechanical shock pulses, three in
each positive and negative cardinal orientation.
The magnitude of the shock is scaled based on the
mass of the device under test but can be up to 150
times the force of gravity. It is the third and final
sequential mechanical stress. As with vibration,
most failures are due to components coming loose
resulting in breakage.
• T5: Short - Once the pack has been put through
significant mechanical stress in the preceding tests,
this evaluation checks to confirm that the cell or
battery can still safely respond to an external short
circuit at elevated temperature. In the case of cells,
it is expected that the cell will heat but not explode
or catch fire. For battery packs with protection, the
criteria are the same but it is the protective device’s
functionality that hopefully mitigates the short, thus
cutting off or at least reducing the flow of current.
In addition to T1-T5, separate groups of cells must go
through two cell-only tests:
• T6 (Crush or Impact) - Which test is applicable is
specified based on a combination of the cell type
(cylindrical, prismatic, pouch, etc.) and the size of
the cell. Both tests can cause internal shorts. As
with the external short in T5, cells will typically get
hot, but fire or explosion is not permitted.
• T8 (Forced Discharge) - This test starts will a
fully discharged cell, and through the use of an
external power supply, forces it into over-discharge
potentially driving the cell into reversal. This refers
to when the voltage is driven down below zero
volts and becomes negative. Put another way, the
cell becomes damaged so that it no longer provides
voltage, but instead acts as a resistor, causing a
voltage drop. This results in the cell heating with the
risk of fire or flame. Our experience is that this test
is a balance of the limits of the cell design coupled
with appropriate discharge current specifications. If
the current specification is too high, the resulting
rate of heating may push the cell too hard, resulting
in excessive heat leading to thermal runaway (fire
and/or explosion).
Finally, rechargeable battery packs that have
overcharge protection must be evaluated to one
additional test:
• T7 (Overcharge) - T7 itself is a simulation of
a battery pack being left in a defective charger
for a day, then removed and put in the shipping
channel for a week. Unlike the T1-T5 sequence, the
sample must be in an operational state for testing,
specifically it must be able to accept charge. The
overcharge voltage and current parameters are
based on the unit’s charge specifications. Failures
of this test are not common. When failures do
occur, they will typically happen during the
overcharge exposure and not during the seven-day
wait period. Most common failures are improperly
sized components in the battery pack’s protection
circuitry that cannot handle the applied overvoltage.
This results in current leaking past the protection
circuitry, which leads to overcharge of the internal
cells and possible thermal runaway.

Note that a separate group of battery packs is used for
this test, although functional samples from T1-T5 can
be reused if sample quantities are limited. The decision
to reuse should not be taken lightly as latent damage
from the T1-T5 sequence may result in failures during
overcharge. This in turn may lengthen the required
time in test and incur additional costs for retesting.
In summary, the new Amendment 1 becomes effective
at the beginning of 2019. It implements a number of
significant improvements to the existing standard that
should benefit the industry with improved efficiency
and standardization. The testing itself carries forward
from the previous version of the standard and is still
both electrically and especially mechanically intense.
JANUARY 2019 IN COMPLIANCE | 49
For those new to needing to achieve compliance,
having a full understanding of what test parameters
will be applied to the design is critical. Additionally,
some degree of pre-testing, either in-house or
outsourced, may be beneficial to improve the
chances of a successful first-time outcome. Finally,
consideration of the impact of stresses being sequential
during T1-T5 testing is also important. As always,
your test lab has significant experience and should be
both able and willing to offer general guidance to help
you achieve your compliance goals.
PRODUCT Showcase
50 | advertiser index

Advertiser Index
A.H. Systems Inc. Cover 2 HV TECHNOLOGIES, Inc. 29

AP Americas Inc. Cover 4 IEEE SPCE 2019 35

CertifiGroup 49 Raymond EMC 31

E. D. & D., Inc. 7 Transtector 3

Haefely Hipotronics 49

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