[RFI] RFI Digest, Vol 199, Issue 3

Sat Aug 3 04:12:45 EDT 2019

Devices that operate above 9 kHz are regulated by the FCC.

The definition of ISM in Part 18 explains why fluorescent RF-lighting devices are regulated as ISM devices:

"(c) Industrial, scientific, and medical (ISM) equipment. Equipment or appliances designed to generate and use locally RF energy for industrial, scientific, medical, domestic or similar purposes, excluding applications in the field of telecommunication. Typical ISM applications are the production of physical, biological, or chemical effects such as heating, ionization of gases, mechanical vibrations, hair removal and acceleration of charged particles>."

Here is a summary of the Part 18 vs Part 15 limits for consumer equipment:

Conducted emissions:

0.009 to 2.51 MHz - Part 18 - 48 dBuV ("maximum")
2.51 to 3.0 MHz - Part 18 - 69.5 dBuV ("maximum")
3.0 to 30 MHz - Part 18 - 48 dBuV ("maximum)
>30 MHz - Part 18 - none
All ISM-band frequencies - Part 18 - none

0.009 - 0.15 MHz - Part 15 - none
0.15 to 0.5 MHz - Part 15 - 66 dBuV to 56 dBuV (q.p)
0.5 to 5.0 MHz - Part 15 - 56 dBuV (q.p)
5.0 to 30 MHz - Part 15 - 60 dBuV (q.p)
Above 30 MHz  - none

Radated emissions:

Below 30 MHz - Part 18 - none
30 - 88 MHz - Part 18 - 20 dBuV/m @ 30 m distance
88 - 216 MHz - Part 18 - 23.5 dBuV/m @ 30 m distance
216 - 1000 MHz - Part 18 - 26 dBuV/m @ 30 m distance
Any ISM frequency - none

Below 30 MHz - Part 15 - none
30 - 88 MHz - 34.3 dBuV/m corrected to 30 m distance
88-216 MHz - 38.8 dBuV/m corrected to 30 m distance
216 - 960 MHz - 41.7 dBuV/m corrected to 30 m distance
Above 960 MHz - 44.8 dBuV/m corrected to 30 m distance

After correcting for the distances for compliance specified in the rules, the Part 18 limits approximately 10 to 15 dB more stringent than the Part 15 limits, so I am not sure why some are claiming that the industry was a powerful lobby to get themselves regulated as an ISM device.  Perhaps they can explain why they believe that manufacturers lobbied to get more stringent limits.

Fluorescent lamps do not operate on any of the designated iSM frequencies that have no limits, so they must comply with the table above.

Ed, W1RFI
ARRL Lab

________________________________
From: RFI <rfi-bounces at contesting.com> on behalf of David Eckhardt <davearea51a at gmail.com>
Sent: Friday, August 2, 2019 4:01:53 PM
To: Gary Johnson <gwj at wb9jps.com>
Cc: Rfi List <rfi at contesting.com>
Subject: Re: [RFI] RFI Digest, Vol 199, Issue 3

Thanks, Gary.  I was not aware of the 8 kHz operation of the 'new'
electronic ballasts.  I still think its a stretch to place them under Part
18, but the FCC has ruled.  The electronic ballast people must have a
strong lobby.  I give up.

When we had this house designed and built out of the High Park Fire in 2012
where we lost everything, I'm glad I specifically specified absolutely no
LED's, no florescent lighting, no CFL lighting, and no (accessible)
SMPS's.  I won, but the new appliances are full of SMPS's not to mention a
few touch panels.   Over the five years we've been in this new house, I've
managed to tame 'most' of the nasty little gremlins for radio astronomy and
amateur radio.  BUT........, when I really want to dig into the noise for
radio astronomy, ALL PC's and laptops must be OFF.

Enough..........  Read my 'rant' on my QRZ page (WØLEV) regarding the
modern digital world and FCC (last paragraph of the QRZ page)..

On Fri, Aug 2, 2019 at 7:43 PM Gary Johnson <gwj at wb9jps.com> wrote:

>  From the FCC site   https://www.fcc.gov/oet/ea/rfdevice
> ------------
> INDUSTRIAL, SCIENTIFIC, AND MEDICAL EQUIPMENT (Part 18)
>
> When electronic-electrical products are used for providing RF energy for
> other than telecommunications applications, such as for the production
> of physical, biological, or chemical effects, such as heating,
> ionization of gases, mechanical vibrations, and acceleration of charged
> particles, these devices fall under the FCC rules 47 CFR Part 18.
>
> Examples include: fluorescent lighting, halogen ballasts, arc welders,
> microwave ovens, and medical diathermy machines.
> -------------
> And it *is* RF because the newer switching ballasts ionize the gas above
> 8 kHz, not 60 Hz. And they are absolutely hideous RFI generators...
>
> Dying a slow death from RFI,
> Gary NA6O
>
>  >
>  > Part 18 exclusively addresses ISM equipment: Industrial, Scientific, and
>  > Medical.  As far as lighting is concerned, Part 18 specifically
> addresses
>  > ONLY "*RF* LIGHTING" which is the only lighting option present in
> Part 18.
>  > Certainly a florescent tube excited to emit light on 60-Hz is NOT "*RF*
>  > LIGHTING".  I fail to comprehend how and why a florescent ballast would
>  > come under Part 18.  Florescent lighting is not "*RF* LIGHTING".
> Possibly
>  > a florescent tube excited to emit light by a Tesla Coil or a close-by AM
>  > broadcast tower (KOB AM in the North Valley of Albuquerque) would/might
>  > come under Part 18, but not standard home florescent lighting.
>  >
>  > Dave - W?LEV
>  >
>
> _______________________________________________
> RFI mailing list
> RFI at contesting.com
> http://lists.contesting.com/mailman/listinfo/rfi
>

--

*Dave - WØLEV*
*Just Let Darwin Work*
*Just Think*
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