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RE: comment on SteppIR was Re: [TowerTalk] New antenna system

To: 'Jim Lux' <jimlux@earthlink.net>, 'Jerry Keller' <k3bz@arrl.net>,"(Reflector) TowerTalk" <towertalk@contesting.com>
Subject: RE: comment on SteppIR was Re: [TowerTalk] New antenna system
From: Steve Katz <stevek@jmr.com>
Date: Tue, 9 Nov 2004 11:00:11 -0800
List-post: <mailto:towertalk@contesting.com>
Hello Jim,

I'll try to steer away from PCs and back towards antennas to keep the thread
in line with the reflector intent.

The Low Voltage Directive compliance testing for consumer electronic
products doesn't cost much; depends who you use as NRTL, how busy they are,
how much prep work you, as the equipment manufacturer, have already done and
other variables.  But I have it done all the time, usually for about $3K.
If FM sells 200 SteppIRs a year for an average of  $700 each, compliance
cost is 2.1% of sales.  Kind of high, but not atypical for a small company.
If they (or anybody) amortize an annual compliance budget of $10K over
products sold, the customers will likely pay it all without knowing they're
paying it.  Part of business.

I agree with you about good engineering practice.  Design for compliance,
whether you get certified or not, and you're usually better off.  Frankly,
the "cost of designing for compliance" is usually "nothing."  It's a matter
of knowing what to do.

I pointed out the product safety stuff only to re-focus what people should
have been annoyed about, instead of simply accepting: If a customer shorts
the user interface cable between two parts of an appliance that are normally
tethered in service -- whether out of stupidity, negligence or accident --
it shouldn't require that parts be replaced.  It's nice to have great
Customer Service and replace stuff that breaks, but it's cheaper and better
to make it simply not break...especially when the cost of doing so is
approximately nothing.

WB2WIK/6

"Nobody needs more than 640k!" -Bill Gates, 1982

> -----Original Message-----
> From: Jim Lux [SMTP:jimlux@earthlink.net]
> Sent: Tuesday, November 09, 2004 10:38 AM
> To:   Steve Katz; 'Jerry Keller'; (Reflector) TowerTalk
> Subject:      comment on SteppIR  was Re: [TowerTalk] New antenna system
> 
> 
> 
> Sadly, this sort of thing is quite characteristic of equipment sold into 
> the ham market.  Just because a manufacturer chooses not to get RTL 
> (recognized testing lab) certification (e.g. UL) is no reason to ignore 
> "good engineering design practice".  I can think of a lot of reasons not
> to 
> try and get certification; cost being the primary one, especially for a 
> product that is not going to be selling in thousand unit quantitites.
> 
> The real problem is that "good engineering practice" (as embodied in the 
> regulatory system) isn't well known outside the commercial manufacturing 
> business, and has diverged substantially from "ordinary ham radio
> practice" 
> over the past decades.  If you look at many companies selling products to 
> hams, a lot of times it starts from someone building one for themself, 
> having someone else say, "gosh, I'd like one of those", and from that is a
> 
> business born.  The problem comes in that at some point, it's changed from
> 
> "making a few copies for my friends" (where regulatory compliance isn't an
> 
> issue) to "making money as a going concern" (where you can't legitimately 
> gripe about having to comply with regulations that everybody else has to 
> comply with).
> 
> A good example is the PC market.  Back in the 1970's and early 1980's, PCs
> 
> were truly a hobby thing.  Not much attention was paid to things like Part
> 
> 15 compliance, UL, etc.  For instance, Los Angeles county has a law that 
> requires all electrical devices sold to consumers be RTL certified. For
> the 
> early PCs one could make the case that these were kits, etc., and they 
> weren't really being sold to "consumers".  And, there just weren't all
> that 
> many places selling them (maybe a dozen in the greater Los Angeles area).
> 
> But, when PCs started to be a consumer commodity, and hundreds of
> "computer 
> stores" popped up, all of a sudden, Part 15 and UL got to be important.
> If 
> you were an IBM (or a Soroc or a Cromemco), and playing by the rules, you 
> had all those certification requirements (and the design and test time
> that 
> went into it).  And, if you were an IBM, you got kind of cranky about all 
> the Taiwanese knockoffs being imported with no certs, no testing, and a 
> distinct lack of "good engineering practice" in the form of omitted parts,
> 
> low safety design margins, etc.
> 
> The FCC stepped in and cracked down hard on the Part 15 side: A good thing
> 
> for us hams, too!  I have some old PCs from the pre-crackdown era, and
> they 
> are truly impressive barrage jammers. It prompted the change from 2 screws
> 
> to 5 screws holding the original PC case cover on, for instance.
> 
> 
> Realistically, I don't think that anybody in the antenna manufacturing 
> business selling to hams is ever going to have the volumes of even a tiny 
> PC manufacturer.  I doubt that the LA County code enforcement types are 
> going to stop Ham Radio Outlet in Burbank, CA, from selling non-UL 
> stickered SteppIR controllers. (Interesting, though, I never thought about
> 
> it before now, maybe they don't sell them over the counter there. )
> 
> It would be nice if wide readership magazines like QST would talk about 
> such things in their construction projects, but I suspect that the 
> editorial review process at QST doesn't facilitate that kind of 
> review.  ARRL's not that huge an organization, and it's kind of an ordeal 
> to get lots of reviewers for articles (especially when they are
> volunteers).
> 
> One can look to the ARRL handbook, but, the target audience for 
> construction and design practices that is the person building one for 
> themselves, not someone going into business to sell them. Building it for 
> yourself, you can legitimately take shortcuts in the design, because you 
> control the environment, and suffer the consequences of design 
> defects.  I'd hate for the "home tinkering" environment to be subject to 
> the constraints of products designed for sale.
>    
_______________________________________________

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