Attachments:
Appendix No. 1 "Electrical Safety Testing of PC Card Modems"
"Telepermit Overview" - Issue 18
APPENDIX No. 1
ELECTRICAL SAFETY TESTING OF PC CARD TELECOMMUNICATIONS DEVICES
INTRODUCTION
The following Appendix covers the issue of electrical safety testing for modems and other devices which are connected to the Telecom network, to CPE SELV power supplies and/or to a customer premises earth. NZECP 3 specifies AS/NZS 3260: 1993 with Amendments 1 & 2 as the appropriate safety standard for such information technology equipment. For New Zealand applications, this Standard is essentially equivalent to the international version, IEC 950: 1991, with its Amendments 1, 2 and 3.
There has been a lot of concern about the interpretation of AS/NZS 3260 in relation to New Zealand regulatory requirements and Telecom's Telepermit requirements. Work done by AUSTEL and by the testing laboratories in Australia came to the conclusion that PC card modems should be classed as "Pluggable equipment Type A". As a result, they should be regarded as 230 V-powered devices for compliance testing purposes. However, most modems sold and used in New Zealand were originally designed for use on the North American market, which uses 110 V power systems. As a result, they do not meet the current Australian safety requirements. The question is whether such devices provide the required level of safety in accordance with the New Zealand Electricity Regulations.
TELECOM'S POSITION
In researching this issue, I have been very conscious of the fact that Telecom's safety requirements have never complied with the current Australian interpretation of AS/NZS 3260. Notwithstanding this, hundreds of thousands of modems have been put into service without any significant problems. This practical experience indicates that these devices do meet the requirements of Electricity Regulation 59. This requires that "there is no significant risk of injury or death to any person, or of damage to any property, as a result of the use of electricity".
Earlier products complying with PTC specifications, but not meeting the current Australian interpretation of AS/NZS 3260 are still on sale and connected in large numbers to Telecom's network. To refuse Telepermits to new products which meet the same PTC requirements would be unfair to the suppliers concerned. Around a hundred modem Telepermit applications alone are being received each year and strict adherence to the Australian interpretation would block a wide range of new products.
OUTLINE OF CURRENT STANDARDS ISSUE
A PC card modem operates primarily at Safety Extra Low Voltage (SELV). The separately enclosed computer power supply is intended to provide the necessary isolation between the 230 V input and this SELV supply. In addition, the network connection of the modem operates at Telecommunications Network Voltage. Safety isolation is required between the network voltage and SELV, and between the network voltage and the computer earth. This isolation has to satisfy the requirements of Reg. 59.
The associated computer is connected to the 230 V supply and its power cable could be incorrectly terminated, such that the phase and earth are transposed. This would result in 230 V being applied to the earth and SELV supplies. This scenario supports the Australian decision to also class the modem as "Pluggable equipment Type A". Countering this, the computer would not be operational, so such a transposition would be immediately apparent. Also, most computers use moulded plugs and the cables are not subject to regular movement or rough usage. Plug replacement is thus not a common event.
If it is classed as "Pluggable equipment Type A", the modem has to meet the "creepage, clearance and thickness of insulation requirements of Supplementary insulation for a 230 V primary circuit". These requirements are in addition to the electrical strength or impulse test that would otherwise be required to confirm adequate isolation between the TNV and SELV/local earth. Clause 6.3.3 of AS/NZS 3260 refers.
INTERNATIONAL STANDARDS DEVELOPMENTS
Since AS/NZS 3260 was published, the IEC TC 74 committee has been working on Amendment No. 4 to the base standard, IEC 950: 1991 (this is now close to publication). Concurrently, they are also working on the next edition - currently termed "Issue 3". However, this might not be published for some time.
Amendment No. 4 incorporates several amendments to Section 6 of IEC 950, which deals with "Connection to telecommunications networks". The working group papers for Amendment No. 4 are now at the public discussion stage, so the changes are very likely to be adopted by the IEC. Changes which relate to safety requirements for card modems are as follows:-
The category "TNV" is to be divided into three separate classes:-
TNV-1 covers circuits whose normal operating voltages do not exceed the limit for an SELV circuit under normal operating conditions, but which may be subject to transient overvoltages from a telecommunications network.
TNV-2 covers circuits whose normal operating voltages exceed the limit for an SELV circuit under normal operating conditions, but which are not subject to transient overvoltages from a telecommunications network.
TNV-3 covers circuits whose normal operating voltages exceed the limit for an SELV circuit under normal operating conditions, and which may be subject to transient overvoltages from a telecommunications network.
By way of explanation, an SELV circuit is a secondary circuit (one isolated from the mains supply by a transformer) so designed and protected that, under normal and single fault conditions, its voltages do not exceed a safe value. In this respect, any voltage not exceeding 42.4 V peak or 60 V d.c. can be considered to be within the SELV range.
Analogue terminal equipment connected to Telecom's network can be considered to be working at TNV-3.
Clause 6.2.1.2 and Table 19 of Amendment No. 4 requires that SELV circuits be separated from TNV-3 circuits by Basic Insulation and by the tests defined in clause 6.4.1, although other solutions are not excluded. Clause 6.4.1 calls up the electrical strength or impulse tests of clause 6.4.2. As a result, PC card modems need to be tested either with 1.5 kV d.c. impulse test to clause 6.4.2.1, or by a 1.0 kV a.c. rms voltage electrical strength test for 60 seconds in accordance with clause 6.4.2.2. In neither case is breakdown permitted, nor shall the current flowing exceed 10 mA. "Breakdown" is considered to have occurred when the current which flows as a result of the application of the test voltage rapidly increases in an uncontrolled manner.
The separation between TNV and earthed conductive parts required by AS/NZS 3260 is one of the current interpretation problems, but Amendment No. 4 drops the present clause 6.3.3 requirement for Supplementary insulation. This clause also clarifies the position with respect to surge suppressors that bridge the insulation. These are required to have a minimum d.c. sparkover voltage of 1.6 times the upper voltage of the working voltage range of the equipment and shall not be damaged during the electrical strength tests of the insulation. A note to clause 6.4.2 specifically states that "There is no Clearance, Creepage Distance or distance through insulation requirement for compliance with 6.4.1".
PROPOSED TELEPERMIT REQUIREMENT
It is not normally acceptable to make use of a draft standard before it is formally adopted, but this seems to be the only practicable alternative to refusing Telepermits and keeping useful products off the market.
The granting of a Telepermit indicates Telecom's permission to connect a product to its network. Whether a product meets all the legal requirements for sale and use in New Zealand is the responsibility of the supplier of that product and the Ministry of Commerce has been asked to clarify the safety requirements. The IEC proposals align with our original test requirements and, as such, support retention of those requirements until such time as the Ministry of Commerce might give a ruling to the contrary.
In the circumstances, it is now proposed that the current "creepage, clearance and thickness of insulation requirements of Supplementary insulation for a 230 V primary circuit" of clause 6.3.3 of AS/NZS 3260 be dropped for Telepermit purposes. PTC 101: 1996 will be based on the final outcome of these deliberations.
