PCB design and high voltages

[Alex/Tubewonder]

In the USA, yes, that works. In the EU, since the testing labs are no longer paid by the government, the game works like this: selling equipment without a "CE" mark is forbidden by civil law, with big fines. Putting a fraudulent "CE" mark on equipment that is clearly non-compliant is a criminal offense in most EU countries. if the testing lab receives a "complaint" of non-labeled equipment, they do a formal test. If that test reveals that the equipment is non-compliant, they are authorized to charge the full price for the formal testing to the manufacturer or seller, as well as most likely being the place that gets the business for re-testing after repairs. So the testing labs have become bounty hunters. They can drum up business by just hunting down non-compliance. In the EU, you **will** get noticed if you have no CE mark on new equipment.

The water is murkier for kits. I didn't look into that. I suspect that one had better be in a position to prove that the kit, assembled to the letter of the instructions and including likely mistakes would pass CE muster. It's hard to argue that a PCB with too-small spacings would get better when assembled. In any case, if it's not CE labeled, the person who builds it may not legally sell it to someone else, and perhaps not even give it away. I'm not an EU lawyer, I just read safety standards and associated literature for several months solid. That is NOT enough. +

The procedures are not exactly as you describe.
Testing labs do what the name says: testing, they're not authorized to chase non-compliant stuff in shops. This is up to Electrical Safety Board to do. They do sample control of whatever crosses EU boarder, currently they have a spy glass on chinese imports. No CE mark means immediate ban. If CE mark is present the importer/distributor or whoever has put the product on the market is asked to present documentation proving compliance in 48hrs. That documentation is called "Technical File" and has to be maintained by manufacturer if he did all compliance certification testing himself or by the accredited test facility that did the testing and issued certificates. The later is the best way to do it.

Now, certification testing by accredited lab is NOT mandatory. Compliance with safety norm is. As manufacturer you are declaring compliance. You are free to declare compliance "by design" but must be able to prove it.

As for tubes amps having no problem with EMC compliance - that is not the case. Have seen quite a few that didn't even though there were no digital clocked circuits in them.
Undersized PT and heavily distorting amp will feed a lot of garbage back into power line. PT will probably overheat anyway leading to non compliance verdict.
Poor grounding scheme will cause the amp to amplify irradiated RF and send it out with mains/input/speaker cable as antenna.
Switching spikes from SS rectifiers if not snubbed are RF sources.

You can build an amp for your own use AT HOME. Officially you're not allowed to use in public venues, lend or sell it unless you put CE mark on it and can prove compliance. But nobody I know cares.

If I receive an amp with 2-prong cord for repair I'm obliged to replace it with earthed 3-prong. If customer refuses I'm obliged to cut the mains cord off. What the customer does after he leaves my shop is not my concern.

I involve an accredited lab from early stages of design. This one is run by senior engineers who are tube geeks themselves, they just love having "something fun and real" to certify as a welcome interruption to all chinese coffee grinders and such.

RoHS is a totally different barrel of bile.

[R.G.]

Well, all you really need to do is make sure that your equipment would comply with the CE mark if a lab ever tested it, and keep a low profile.

Aye, there's the rub.
1. "... make sure that your equipment would comply..."
The ONLY way to do that is to have a certified lab test it, unless you yourself are an experienced compliance tester. It's a little like saying "all you need to do to successfully remove a brain tumor is know all that surgery stuff so you would be licensed as an MD and pass the necessary exams and so on". Worse yet, some of the issues are ambiguous, and whether you would pass can turn on the interpretation of a single word in a phrase of the standard.

I was proud of the fact that I pointed out some issues in the standard to the reviewers I hired. But they in turn pointed out items that needed changed even though I had been through the standard with the design documents line-by-line-by-line multiple times.

The procedures are not exactly as you describe.
Testing labs do what the name says: testing, they're not authorized to chase non-compliant stuff in shops. This is up to Electrical Safety Board to do.

That's why I put "complaints" in quotes. No they are not authorized to go chasing down business. But someone brings issues to the Electrical Safety Board's attention . You can also be waylaid and not be able to keep a low profile if you have any competitors who might not like your products. It's a system that's rife for corruption and spite.

Now, certification testing by accredited lab is NOT mandatory. Compliance with safety norm is. As manufacturer you are declaring compliance. You are free to declare compliance "by design" but must be able to prove it.

I may have not been clear. Yes, "Safety" is mandatory, as explained in the standards. That is, you are responsible for any damages to people, property, or animals that results from unsafe conditions in your product. However, compliance with safety standards is no longer presumptive safety as it once was.

In the day when European testing was nationally mandated, approval by a compliance lab meant that you WERE by legal definition, safe, and hence not liable. Now, the standard is a de-facto minimum. If you do not at least comply, you could easily be argued as being inattentive to safety minimums. But if someone gets hurt or killed, you are still liable, even if you met the standard. However, if you can prove you met the minimums, you cannot be said to be reckless and irresponsible.

What the current system does is perform responsibility splitting. If you have a certified lab do a report and you put on your CE mark, then you can tell people who bring claims to go argue with the lab. It's a version of the old adage that if there are more than two signatures on the form, the blame can never be placed accurately.

As for tubes amps having no problem with EMC compliance - that is not the case. Have seen quite a few that didn't even though there were no digital clocked circuits in them... Poor grounding scheme will cause the amp to amplify irradiated RF and send it out with mains/input/speaker cable as antenna. Switching spikes from SS rectifiers if not snubbed are RF sources.

I'm glad to see someone aware of this. Most people have no idea.

[R.G.]

And just wait until the RoHS non-compliance fines start rolling in....

That turns out to be a "bookkeeping tax". All you have to do to pass ROHS is to be able to show that all the parts and materials you put into your amps were represented to you as ROHS conforming. That then lets you off the hook in favor of pursuing the much fatter target of a part manufacturer committing fraud.

[Steve Conner]

Unfortunately, a uC or DSP is necessary if you want to implement MIDI switching or digital reverb/effects...!

Well, we're talking about actual tube amps here, symbols of an era when technology was simple enough that people had a hope of understanding it. I personally draw the line at op-amps, maybe OTAs, in my homebuilt music gear. If I wanted MIDI and digital FX, I'd buy a Line 6, since they already have that down.

I'm looking forward to the Line 6 DSP stompbox DDK coming out though! I think that's the same Freescale Symphony DSP that RG mentioned, though I always think of those as the Motorola 56k series. I've written stuff for the ADI 21xx and TI 67xx DSPs before, and I know a guy who does amazing audio things with the Microchip dsPICs.

All I'm trying to say is that the whole RoHS/CE thing is a nightmare. I'm not debating this. I'm just wondering what it means to a mom and pop shop. I guess they have two options: close up, or go underground and hope they don't come onto anyone's radar. I took the option of working as an EE in industry and leaving amp building as a hobby. It means I end up designing boring industrial electronics instead of groovy boutique amps, but it also means someone else is paying for the compliance testing, and someone else getting sued if it goes wrong, which suits me just fine.

[raiken]

All I'm trying to say is that the whole RoHS/CE thing is a nightmare. I'm not debating this. I'm just wondering what it means to a mom and pop shop. I guess they have two options: close up, or go underground and hope they don't come onto anyone's radar.

And that is the heart of the matter. These weasel bureaucrats, politicians, and environmental do-gooders are killing the spirit of independence and making small businesses nearly impossible to run, either from being inundated with paperwork, or by being forced to pay lots of money for ever-changing regulatory compliance. It is quite sad.

Randall Aiken

[GainFreak]

And that is the heart of the matter. These weasel bureaucrats, politicians, and environmental do-gooders are killing the spirit of independence and making small businesses nearly impossible to run, either from being inundated with paperwork, or by being forced to pay lots of money for ever-changing regulatory compliance. It is quite sad.

It's also called Corporatocracy.

[R.G.]

And that is the heart of the matter. These weasel bureaucrats, politicians, and environmental do-gooders are killing the spirit of independence and making small businesses nearly impossible to run, either from being inundated with paperwork, or by being forced to pay lots of money for ever-changing regulatory compliance. It is quite sad.

Amen.

However, by and large in the USA we get the government we deserve. We have inherited a simple, effective way to get rid of the weasels. That we do not use it is a tragedy. There is a reason HOR terms are two years. What kills me is that the whole congress does not turn over every few years. I find it amazing that people can be unaware of these issues; and never connect up the dots that having a government in your shorts in any way is a Bad Thing.

There is a book that's worth reading. It's called "A Parliament of Whores" by P.J. O'Rourke.

[Alex/Tubewonder]

From PCB creepage distances to government in your shorts. Hilarious, you guys are ....creepy

Anyway, there was a case of one company reporting a competitor for RoHS non-compliance. Both got investigated and guess which one was found non-compliant?

Here in Sweden the Electrical Safety Board has it's own inspectors who pick products randomly or act upon a report of a documented electrical mishap. One distinct difference between EU Safety Boards and UL in US is that UL is a profit driven Inc.
Complaining that your cat died when you attempted to dry its fur in a micro does not count for anything other than having yourself declared an idiot and doing time for cruelty to animals.
The only state agency that will investigate on anonymous tip is the Tax Office.

Corruption is a funny thing, definition varies with geography. We don't care about our politicians sex life unless they get involved with minors or porn. Their job is in danger if they use a government issued credit card to buy toys for their kids or do cut and paste tricks with job related expense receipts.

An interesting thing: a product liability insurance policy with EU insurance company states clearly it does not cover USA. For that you need additional policy that costs 5x more. Thanks to great American tradition of suing everybody for anything. What if all these lawyer fees were put to getting stuff properly tested and certified?

BTW. CE mark also implies that the product is accompanied by a user manual including detailed safety instructions. Mine has 5 pages of them. Warranty & product registration card must be signed by customer and returned by registered mail. If the statement: "I have read and understood safety instructions" is not initialed all bets are off.

[Enzo]

No argument from this American. I don't care about politicians' sex lives either. Unfortunately I am a minority. Over here if we can point a finger and find someone to blame for something, we consider the job done. We don't really try to change anything, we jist want that AHA! moment, and then we forget it.

It is a fine old American tradition swapping stories about who sued whom for how silly a thing. "Did you hear about the guy who...?" I am sure they are really the exception, but we hear about incidents like the fellow who dropped a car battery on his foot as he was trying to install it himself, and successfully sued the battery manufacturer.

In some parts of the world, if you bring suit and lose, then YOU are responsible for the other party's legal expenses. I like that plan, that would stop a lot of frivolous suits.

[Steve Conner]

Anyone know how to calculate creepage and clearance for one of these?
http://www.neighborhoodvalues.com/nv.../misc/35kc.htm (notice that it was in an online store: someone sold it)

Alex: The Scandinavians are so sensible, they could make even the most messed-up political system work fine. I've never visited Sweden, but I've been to Norway and Denmark on business and loved it there. I'd consider emigrating if it weren't for the price of beer

[R.G.]

Yeah, but you folks in Sweden are **sane**. Not so in the USA.

[R.G.]

Anyone know how to calculate creepage and clearance for one of these?
http://www.neighborhoodvalues.com/nv.../misc/35kc.htm (notice that it was in an online store: someone sold it)

Actually, it's possible for that one that passing creepage/clearance was a breeze. An interlock switch on the cover would be all that was needed.

Of course there are other sections of the standards that might not let that one pass today.

[Alex/Tubewonder]

Yeah, but you folks in Sweden are **sane**. Not so in the USA.

We do have our share of people endowed with "alternative intelligence" in every walk of life. It's not all nice and cosy over here even though it may look this way from across the pond.

[Tubis]

You can build an amp for your own use AT HOME. Officially you're not allowed to use in public venues, lend or sell it unless you put CE mark on it and can prove compliance. But nobody I know cares.

I dont care, and there is some of my crapy jobs out there on the swedish roads I will do like Clinton does, deny, deny, deny. I did not have solder intercourse with that amp

[Aurora]

Hi guys.. I'm an absolute newcomer to this forum....
55 yrs EE in instrumentation and telemetry.. lifelong "audiophool" and snake oil sceptic.
Dumped in here because of a guitar freak son.. ( otherwise he's a good lad...)


[QUOTE=Alex/Tubewonder;67572]
Complaining that your cat died when you attempted to dry its fur in a micro does not count for anything other than having yourself declared an idiot and doing time for cruelty to animals.
[/QUOTE

Even if this and other stories like this may be "designed", I've often wondered how the US legal system came into this "I'll sue you and you'll sue me" situation... I recently read a report that this legal lunacy is costing the US society something like 5.000.000.000.000 $, all together.......? Hm.......

But, to the case..
The CE and UL stuff is of course applicable to all aspects of "homegrown" electronics, not only musical related. I started loking into this some years ago, but dropped out along the way. Most of my passtime audio work has been with loudspeakers, although I've made my fair share of amps, but I've never sold anything to other than fairly close friends. Now this questions is again relevant, 'cause of my sons interest in guitars, as there's the chance that whatever I may build may be traded for something else, in the eternal quest for "the holy grail of tone.."

Alex.. do you happen to have any links to relevant documents regarding CE and safety...?
For the rest of you - the old pre CE swedish and Norwegian regulations very mostly identical, and for most a certificate from the old swedish SEMKO ( official swedish testlab) was automatically accepted by the norwegian NEMKO, and vice versa....Norway and Sweden were known to have some of the strictest regulations for electrical safety in the world...

Halgeir Wold
Norway