For the last few years, SABS TC73 and later, ICASA, has been working on the radio interference legislation in South Africa, with the following intentions:
* To harmonise the overall requirements with our major trading partners, particularly Europe.
* To streamline the way in which future changes to the requirements can be made, to allow for new product categories, without requiring an act of parliament, or a Government Gazette entry for such product categories.
Current situation
At present, the Telecommunications Act (which contains the old Radio Act machinery) embodies the limits for radio interference for various product groupings, in tabular form. The limits and categories are based on the various CISPR emission standards, mainly those pertaining in 1984. The fine detail of how the tests are to be done, what equipment is to be used, calibration methods, etc, are not stated in the legislation, although it is widely known that the sources are those in the CISPR standards. This has led to the unfortunate position that the methods are not well understood. It was probably logical to do the legislation this way at the time, but we now live in a world of such dynamic change, that streamlining was seen to be essential.
Phase 1: The first step in the process will be the removal of the limits from the legislation, and refer directly to the relevant standards. This process is largely complete, and the necessary instrument is expected to be published in the Government Gazette entry before the end of July 2003.
It will be obvious to everyone in the electrical and electronics industries that this will, firstly, allow the latest issue of the adopted standards to be required for the various products, without having to issue a new Government Gazette and, secondly, give everyone the ability to fully understand the origin of the emission limits.
Phase 2: This is a much larger project, again started some years ago, and takes the interference legislation to the next step, by including the requirement for 'immunity' (susceptibility) in the legal instrument. This is much more difficult to introduce than the changes in Phase 1, because the electronics industry has not had to comply with most of the immunity standards. This aspect of performance first became mandatory in Europe about 10 years ago, for all imported and locally-produced equipment, and formed an essential part of the familiar CE mark.
Since this is such a new aspect of performance assessment, the legislation will be phased in over a period of time. This was recognised as being essential because:
* Design engineers are not fully familiar with immunity standards and mitigation methods.
* Equipment which is in the design phase would have to be redesigned to be compliant with the new standards.
* Some products, yet to be launched, have had significant investment in marketing, and it would be unrealistic to expect such equipment to require redesign before launch.
* Products already on the market will have to be given some form of dispensation, either to allow time for compliance, or continued marketing of the model until natural end of the line.
Some imported products already carry the CE mark, and thus comply with the relevant standards. Such equipment does not need a delay in the legislative process, and thus should have mandatory requirements immediately. However, the problem with requiring compliance is that such a requirement could be viewed as a barrier to trade, one interpretation being the breaking of the rules of the WTO, to which SA is a signatory.
Emerging standards
With the wide range of new electronic devices entering the market, one major problem is to ensure that any legislative process is able to 'turn on a dime', in the sense that a new technology would need to be controlled from an EMC point of view, as soon as it is available on the market. If the standards were embedded in the legislation by reference to the standard number, a new Government Gazette entry would be required for each new product group which requires a new standard. This situation would quickly become unmanageable, since about 10 new technologies enter the electronics industry each year.
Implementation
The way that this was handled in Europe is that the legal instruments, the 'Directives', have a reference to the 'Official Journal' (OJ) - a listing of requirements for each product group. The Directives and the OJ can be accessed directly on the Web.
It has been decided that South Africa should follow this model, with some administrative differences. (The items below still have to be ratified by Standards South Africa (STANSA)).
* The list of product group against date of mandatory compliance and relevant standards will be maintained by Standards South Africa (formerly Standards Division of SABS), and will be available on the Web site of ICASA, free of charge.
* The list will be called the 'Official List', and will be referred to by a SANS number, still to be issued.
* The list will be maintained by STANSA TC73, approved by ICASA and issued by STANSA TC80 when full agreement is reached.
Future changes
It is recognised that this complex plan may have problems, and it is expected that the public will be given the opportunity to comment on the proposed legislation, using the normal Public Hearings routine.
Training: The inclusion of immunity countermeasures requires a somewhat different approach from that used for emission reduction, and the phase-in period is intended to be used by manufacturers and importers as an opportunity to ensure that their teams are technically ready for the new requirements. To this end, various educational institutions and EMC bodies will be presenting training courses and seminars, targeted at all levels of the electrical industry, including the electronic and the electrical design engineer, installer, management and procurement. Some of these are listed in the Table, the absence of other bodies does not imply that they do not offer training.
Information provided by Connecta, 011 463 2240. For more information contact Eric Winter, EMC Assist, 021 701 7345, [email protected]
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