EMC/EMI

Military and Aerospace EMC: What is the RTCA?

In Compliance Magazine -

Greetings. I am Patrick André, an independent EMC consultant in the Pacific Northwest. Having spent my career in EMC design, testing, and troubleshooting, mainly in the aerospace and military industries, I have had a chance to answer many questions. In this blog, I’ll address some of those questions and share some unique aspects of EMC in the military and aerospace field. Let me know if there is a specific aspect of this field you would like to see covered. Let’s begin.

One question I have heard is, “What is the RTCA?” In the EMC field, most people know the RTCA as the group that creates the aeronautic environmental standard DO-160. However, beyond establishing tests and test levels for environmental testing of avionics, the RTCA’s work reaches far beyond DO-160.

The Radio Technical Commission for Aeronautics, now known as RTCA, was established in 1935 with a focus on the standardization and assurance of safety of radio communication and radar systems. This led to other developments, such as a common system for air traffic controllers across the United States. The work is not specifically performed by the RTCA but rather by groups and committees of industry experts and specialists in a specific field. In doing so, industry has a direct say in how standards are established while recognizing that the quality of these standards must be maintained at a high level.

The RTCA is a private, not-for-profit organization and not an agency of the US Government. The organization covers the hardware and software used for flight control and navigation, collision avoidance, audio systems, night vision systems, flight deck displays, weather detection, among other areas. For example, portable electronics used by passengers and flight crew must also be researched and regulated for safe use on commercial aircraft and to ensure that avionics are not affected.

The RTCA has members from over 460 commercial aerospace companies and other interested corporations and groups. The standards, operational situations, architectures, and other documents that are within RTCA’s control are in the form of Minimum Aviation System Performance Standards (MASPS), Minimum Operational Performance Standards (MOPS), Safety & Performance Requirements (SPR), Interoperability Requirements (INTEROP) and other publications. There are about 500 documents currently available from the RTCA, with many available in either hard copy or electronic format.

The RTCA works with the FAA in the United States and with EUROCAE – The European Organization for Civil Aviation Equipment. EUROCAE and the RTCA often work in cooperation with each other to create common standards and regulations. For example, DO-160 in the United States has a EUROCAE counterpart, ED-14, which both groups have agreed to in totality.

Committee meetings are typically open to the public. However, voting and suggestions for changes are allowed only by members of the RTCA. However, input from all aspects of the aerospace industry is welcomed.

The website for the RTCA is available here.

Next month, we will look at DO-160 specifically, its development, and the upcoming revision.

The post Military and Aerospace EMC: What is the RTCA? appeared first on In Compliance Magazine.

FDA Amends Quality System Regulations for Medical Devices

In Compliance Magazine -

In an effort to stay current with new and updated international standards, the U.S. Food and Drug Administration (FDA) has amended its quality system regulations applicable to the manufacture of medical devices.

In a Final Rule published in early February in the Federal Register, the FDA amended its current good manufacturing practice (CGMP) requirements for its quality system (QS) regulation applicable to medical device manufacturers. The amended requirements now incorporate by reference ISO 13485:2016, Medical devices—Quality management systems—Requirements for regulatory purposes. The FDA says that the change is part of its effort to harmonize its quality management systems requirements for medical devices with those adopted by other regulatory agencies.

The FDA’s final rule regarding the changes to its current CGMPs takes effect on February 2, 2026. Until then, device manufacturers must continue to comply with the FDA’s QS regulation.

Read the FDA’s quality system regulation amendment as published in the Federal Register.

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U.S. and EU Sign Joint Cybersafe Products Action Plan

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The U.S. and the European Union (EU) have signed an agreement to work collaboratively to strengthen the cybersecurity of Internet-of-things (IoT)-capable hardware and software products used by consumers.

According to a joint press statement issued in late January by the European Commission and the White House National Security Council, the Joint Cybersafe Products Action Plan is intended to foster technical cooperation between the U.S. and the EU, in an effort to align their respective cybersecurity requirements. The ultimate goal of the Joint Action Plan is for the signatories to achieve mutual recognition of cybersecurity labeling programs and regulations for IoT devices.

The Joint Cybersafe Products Action Plan was immediately endorsed by Jessica Rosenworcel, Chair of the U.S. Federal Communications Commission (FCC). In a separate statement, Rosenworcel referenced the FCC’s efforts to establish its own cybersecurity labeling program, building on work by the National Institute of Standards and Technology (NIST), and welcomed the opportunity to actively collaborate with their counterparts in the EU to reduce unnecessary cyber risks for consumers.

Read the joint press statement issued by the U.S. and EU about the Joint Cybersafe Product Action Plan.

Read Rosenworcel’s remarks about the U.S./EU Action Plan.

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FCC Makes AI-Generated Robocalls Illegal

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In a landmark decision, the U.S. Federal Communications Commission (FCC) has unanimously ruled that robocalls made with voices generated by artificial intelligence (AI) tools are illegal.

In a Declaratory Ruling issued in early February, the Commission summarized its determination that calls that include AI-generated voices are “artificial” under the Telephone Consumer Protection Act (TCPA) and, therefore, illegal. Under the TCPA, violators are subject to FCC enforcement authority, including fines and actions to block calls from telephone carriers that facilitate illegal robocalls. In addition, individual consumers are empowered under the TCPA to bring lawsuits against robocallers.

The Declaratory Ruling, which takes immediate effect, is based in part on a Notice of Inquiry issued by the Commission in November 2023 to solicit public input on how AI and AI-influenced technology can or will impact calling and texting processes and the extent to which such technology could compromise consumer privacy under the TCPA.

The FCC’s decision to make AI-generated robocalls illegal also has the support of a coalition of 26 State Attorneys General across the U.S., who urged the FCC earlier this year to restrict the use of AI in marketing phone calls.

Read the FCC’s Declaratory Ruling on AI-generated robocalls.

The appeal from the State Attorneys General supporting the FCC’s action is summarized in a press release issued by the Pennsylvania Attorney General.

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Charged Device Model ESD Testing

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Introduction

The charged device model (CDM) electrostatic discharge (ESD) testing is useful in recreating the potentially destructive discharge mechanisms in automated component handling systems and similar situations where semiconductor devices are packaged and assembled. In these situations, the component becomes highly charged and is then quickly discharged when it encounters a conductive object that is at a lower electrostatic level. This encounter often results in dielectric breakdown and failure of the component. Since this event involves a low-impedance, metal-to-metal transfer of charge, with peak currents reaching tens of amperes within a very short amount of time (within nanoseconds), and there are multiple sources of parasitics involved, it is very difficult to reproduce. Therefore, to increase reproducibility and trust in any semiconductor component manufacturer’s claims of ESD robustness encountered in packaging and handling of their device, a standard (reference 1 is an example) was established to clearly define field-induced CDM ESD test methods for these devices.

Purpose of a Standard CDM ESD Test Method

A standard CDM ESD test method aims to establish a test method that accurately reproduces CDM failures and provides dependable, repeatable CDM ESD test conclusions from tester to tester (equipment to equipment), irrespective of component type or packaging. Accurate classification and comparison of the CDM ESD sensitivity (susceptibility) levels of different semiconductor components is possible by obtaining reliable test data from this standardized CDM test method.

CDM ESD Tester

The normative section of the standard (reference 1) describes the “field-induced” (CDM-FI) CDM test method. One of the informative annexes describes an alternative “direct-contact” (CDM-DC) method. However, the CDM-DC method does not produce results that compare well with results using the hardware and field-induced method specified in the body of the standard, so this CDM test method is not described further in this article.

The CDM-FI tester assumes the use of a resistive current probe. A field plate sits at the bottom of the tester, on top of which sits a dielectric layer. The device under test (DUT) is placed on top of the dielectric layer. Connected to the side of the field plate is a charging resistor (nominally 100 MΩ or greater), and this is connected to switch K1, the purpose of which is to switch between charging the field plate using a high-voltage supply and grounding the field plate.

Placed above the field plate is a ground plate with a hole that allows the pogo pin (ground pin) to protrude through it. The pogo pin is connected to the center conductor of 50Ω coaxial cable, the output of which connects to the 50Ω input of an oscilloscope. The standard specifies the pogo pin to ground plane connections as a 1 Ω current path with a minimum bandwidth (BW) of 9 gigahertz (GHz). These two items make up what is called the current-sensing element in the standard. The entire ground plate is connected either to ground or to the field plate through the high-voltage supply, depending on the position of switch, K1.

Waveform Characteristics

Waveform characteristics are specified without additional passive or active devices (such as ferrites) in the probe’s assembly. This requirement may affect compliance of existing CDM-FI testers which might have used components like ferrites to obtain the correct waveforms. If you have a CDM-FI tester built before 2017, consult your CDM ESD tester manufacturer to see if this requirement is an issue.

For exact waveform requirements of the standard, refer to Figure 2 – CDM characteristic waveform and parameters, Table 1 – CDM waveform characteristics for a 1 GHz bandwidth oscilloscope, and Table 2 – CDM waveform characteristics for a high-bandwidth (≥ 6 GHz) oscilloscope).

Parasitics

For anyone building their own CDM-FI tester, the standard cautions about the potential for having too large of parasitics in the charge and discharge paths because having these unwanted resistance inductance-capacitance (RLC) parasitics in the equipment will greatly influence the test results and comparison of these results with those obtained from complaint CDM-FI testers.

Specifications for Various Elements of the CDM-FI

Exact specifications for each part of the CDM-FI are described in detail in the standard and are not repeated here. This includes exact specifications for the current-sensing element (resistance plus/minus tolerance, frequency response, and maximum roll-off), dimensions of the ground and field plates (plus/minus tolerance, surface flatness), material composition and thickness (plus/minus tolerance) for the dielectric layer, etc.

Common CDM ESD Test Standards

Other CDM ESD test standards often encountered in the industry include JS-002, AEC-Q100-011, AEC-Q101-005, and JESD22-C101. Reference 1 is based on ESDA/JEDEC Joint Standard ANSI/ESDA/JEDEC JS-002, which resulted from merging JESD22-C101 and ANSI/ESD S5.3.1. Reference 1 contains the essential elements from these original CDM ESD standards, and cooperation between ANSI, ESDA, JEDEC, and the IEC took place in creating reference 1.

Qualification and Verification of the CDM-FI Tester

The standard requires periodic tester qualification, waveform records, and waveform verification, i.e., “The CDM tester shall be qualified, re-qualified, and periodically verified….”

Any change to the main elements of the CDM-FI tester (described previously) requires waveform verification. Luckily, the standard provides what waveform capture hardware is required along with the waveform capture setup and procedure. The standard also provides a detailed qualification/requalification procedure that appears easy to follow. The standard states: “Maximum time between requalification tests is one year.” Suppliers of CDM-FI testers may have their own recommendations for requalification that savvy users of the equipment will follow.

Pro Tip: If you have ever been caught in a situation where you potentially have shipped a non-compliant product because you later found out your tester was not producing the correct output waveform (not a fun situation), you will want to develop a process to re-check your CDM-FI tester’s waveform characteristics as often as feasibility justified (perform a cost/benefit and risk analysis to determine your best options).

Summary

This article described the basics of CDM ESD testing using the FI method and why it is important to those who produce semiconductor devices. It included the construction of a CMD-FI tester, some of the nuances involved, and proper qualification and verification of its waveform. Hopefully, you find this information useful.

References and Further Reading
  1. IEC 60749-28:2017, Semiconductor devices – Mechanical and climatic test methods – Part 28: Electrostatic discharge (ESD) sensitivity testing – Charged device model (CDM) – device level.

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Let’s Talk About This: X1 vs X2 Capacitor Types and How to Select the Correct Type

In Compliance Magazine -

Background Information

X-type capacitors suppress differential mode conducted emissions in applications such as switch-mode power supplies, DC-DC converters, variable-speed motor drives, and other similar devices. The X designation means they are applied line-to-neutral, as shown in the simple diagram below.

The Issue

Manufacturers of X capacitors have their capacitors tested and certified by a Nationally Recognized Testing Laboratory (NRTL), and a certificate is provided. X-type capacitors are considered a safety critical component of the end-product, and as a compliance engineering professional, it is crucial that you know which subclass to use. Not selecting the correct sub-class for the end-products’ application will result in a non-compliance that will cause re-design and delay of production release of the product. Switching is not a simple process if you select an X2-rated capacitor and need an X1 instead. First, you must find a suitable X1-rated part and try to make it fit into the existing design. X1-rated capacitors are physically bigger than X2-rated parts.

X-type Capacitor Subclasses

The standard most often used to certify X (and Y) capacitor types is IEC 60384-14. This standard specifies three different subclasses of X-type capacitors depending on their peak impulse voltage rating.

X3 Subclass

The subclass X3 has a peak impulse voltage rating of less than or equal to 1.2 kV. This is not too high of an impulse rating, so only use X3-rated capacitors in benign environments (those protected from overvoltage transients). Since it is not to be used for robust design, the X3 subclass is not discussed further in this post.

X2 Subclass

The subclass X2 has a higher peak impulse voltage rating than the X3 type. The X2 subclass has a peak impulse rating of less than or equal to 2.5 kV.

X1 Subclass

Finally, the subclass X1 is even more robust than the X2 capacitor type. It has a peak impulse rating of greater than 2.5 kV and less than or equal to 4.0 kV.

Which Subclass Type Do I Use? X1 or X2?

To determine which subclass type to use (X1 or X2), you must know the end-product’s overvoltage category of the intended environment. This is something that is usually determined early in the product development cycle.

IEC 60664-1 (latest edition is dated 2020) describes the overvoltage categories. There are four overvoltage categories, designated as I, II, III, and IV. Devices installed in category IV locations are subjected to the most severe transients (surges), whereas category I locations are the least severe, protected environments. This post focuses on categories II and III. Examples of category II locations are household appliances plugged into the standard home wall outlet. Category III locations are closer to the voltage supply and subjected to harsher transient conditions. Examples are switches in the fixed installation and equipment for industrial use with permanent connection to the fixed installation.

Annex B (informative) of IEC 60664-1 describes nominal voltages of mains supply for different modes of overvoltage control. See Table B.1 – Inherent control or equivalent protective control. This table is something you need to look at.

For example, select 300V as the voltage line-to-neutral derived from nominal voltages AC or DC. The rated impulse withstand voltage for the equipment is provided for each overvoltage category. For category II, it is 2.5 kV; for category III, it is 4.0 kV.

Given this information, if your end-product is installed in an overvoltage category II location, then an X2-rated capacitor is acceptable. However, if it is installed in an overvoltage category III location (a location that requires a rated impulse withstand voltage of 4.0 kV), then an X1-rated capacitor is required.

What If I Select an X2 but Require an X1?

All is not lost if you inadvertently select an X2-rated capacitor but require an X1. You can install a clamping device (such as a metal oxide varistor) across the line that limits the transient overvoltage seen by the rest of the circuit to less than or equal to 2.5 kV and work with your NRTL to accept it. This workaround has some risks as it depends on the NRTL’s policy for dealing with this situation, which could change anytime.

The post Let’s Talk About This: X1 vs X2 Capacitor Types and How to Select the Correct Type appeared first on In Compliance Magazine.

EU Commission Proposes More Time for Compliance with In Vitro Diagnostics Regulation

In Compliance Magazine -

The Commission of the European Union (EU) has proposed providing manufacturers of certain medical devices with additional time to comply with the requirements of the EU’s In Vitro Diagnostic Medical Devices Regulation (IVDR).

Originally published in 2017, the EU’s IVDR established a new regulatory framework applicable to in vitro devices (IVDs). Requirements under the IVDR are scheduled to take effect in May 2025 for high-risk IVDs and May 2027 for lower-risk devices.

However, according to a press release issued in late January, the Commission is concerned that many IVDs currently on the market still do not comply with the new requirements, including a number of what it classifies as high-risk IVDs used to test for infections in blood and organs.

Accordingly, the Commission has proposed extending deadlines for compliance with the IVDR requirements as follows:

  • For Class D devices, including high individual and public health risk devices such as HIV or hepatitis tests, a deadline of December 2027;
  • For Class C devices, including high individual and/or moderate public health risks devices such as cancer tests, a deadline of December 2028; and
  • For Class A and B devices, including lower-risk devices such as pregnancy tests and blood collection tubes, a deadline of December 2029.

According to the Commission’s press release, their proposal to extend the IVDR transition deadlines will now go to the EU Parliament and Council for their review and adoption.

Read the EU Commission’s press release detailing its proposed changes to the implementation dates of the IVDR.

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FCC Adopts Guidance on Orbital Space Debris

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The U.S. Federal Communications Commission (FCC) has issued a guidance to clarify requirements for space satellite operators under its orbital debris mitigation rules.

In an Order on Reconsideration issued at the end of January, the Commission addresses a number of questions posed by satellite operators and other petitioners about its debris mitigation requirements. Specifically, the Order addresses questions dealing with satellite maneuverability disclosure requirements and the use of “free-flying” deployment devices.

The Order also offers guidance on methods that can be used by satellite operators to conduct re-contact risk analyses, as well as its requirements for assessing and limiting the release of persistent liquids in space.

These latest actions by the Commission are intended to support continued investment and innovation on the deployment of space-based services, consistent with its Space Innovation agenda, while also taking steps to advance space safety.

Read the FCC’s Order on Reconsideration on orbital space debris.

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