nce upon a time, a fast growing company, Z-Comp*, marketed "Toaster", a low-priced, high performance USB computer accessory that was selling very well--so well that a competitor, MegaBull*, began to notice.

As part of market research, MegaBull bought three Toasters to run some benchmark tests and see if they could learn anything.

The MegaBull regulatory engineers noticed that the Toaster didn't have the usual FCC and safety markings, and the manuals had no statements of compliance. For an a "few dollars" ($1500) they tested the Toaster at an accredited EMC lab. To ensure that devices all "play well together", the FCC limits the "noise" that can be emitted. The toaster failed--miserably--some emissions were 15 decibels over the limit! MegaBull then complained to the FCC and provided the test data.

For a couple of months, things were going great at Z-Comp. A couple of customers reported some interference on their monitors while using the Toaster, but support just said "Sorry, it must be your monitor." Z-Comp had no idea the FCC was about to knock on their door. It takes time for things to work through the bureaucracy, but the FCC finally called and started asking a lot of questions. Z-Comp management was on the hot seat. To resolve the situation without fines, Z-Comp had to redesign their product, recall $1.05M worth of Toasters (plus shipping!). Some "heads rolled" but it was to late. The final blow was when one of the units (due for recall) caused a small fire with significant damages. A civil lawsuit was filed against Z-Comp, and since they had not done any safety testing or certification, you know what happend--they lost!

Luckily, nobody was seriously hurt, but the company never really recovered. They learned some lessons and changed their ways, making sure products met all the EMC and safety requirements. But it was too late. The FCC and court troubles were part of the public record, and their competitors' sales staffs were well versed in warning customers that Z-Comp products mean "trouble."

The End

*Company names and product are fictitious.

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Why operate this way? Safety issues can be even more problematic. Most electrical products sold in the US require safety certification through state and local law, and all workplace equipment must be certified to meet the Occupational Safety and Health Administration (OSHA).

• It is company policy to comply with regulatory requirements. The requirements must be known, understood, and documented. This is very important for the design team.
• Sufficient resources are available to obtain and monitor compliance.
• Third party test labs are carefully selected and used efficiently.

Solutions
For smaller companies, it may not make sense to hire a full-time engineer to keep abreast of the regulations and how they effect the products. Changes to a design may require additional testing, but this is not always the case. Labs are not allowed to give free (or paid) advice specific to a product design. They will usually "err on the side of testing", and this can be expensive.

I have over 5 years working with internationally recognized test labs (e.g. UL, , CSA, Nemko, TUV) including hands-on safety testing and CB reports for computer equipment (IEC60950) and medical devices (IEC60601). With this experience, I can help avoid pitfalls that cause problems in the regulatory review and tests by:

• Evaluating safety related issues in the product. This includes component certification and materials review, and what needs to be submitted to the lab.
• Managing the product at the EMC test lab. Labs charge $200/hr. and up. To get maximum value, it’s important to have your “ducks in a row” when it comes to test plans, samples, and monitoring the product during tests.
• Training in Standards Training--customized to fit the audience, from engineers to sales and marketing.

Please contact me (email link below) if you have questions or want to discuss regulatory matters in more detail.