Campaign Wall Dimmers Out of Scope—For Now

Campaign Wall Dimmers Out of Scope—For Now

This piece was originally published in the March/April 2019 issue of electroindustry.

Alex Boesenberg, Senior Manager of Regulatory Affairs, NEMA

This past December, the Engineering Planning and Standards (EPS) branch office of the Canadian ministry for Innovation, Science and Economic Development (ISED) published the fifth revision to its Standard for radiated and conducted emissions for lighting products, ICES-005. This publication capped a year of staunch advocacy and technical work.

A small change to wording in the scope section of the draft for comment document caused significant concern for NEMA Members, especially the Lighting Controls Section. The words “ex. wall dimmers” were added to that section of the draft, ostensibly tagged as a clarification. If allowed to proceed unchallenged, these words would have brought all wall box dimmers under the scope of the Standard, causing millions of dollars in redesign and testing, gaps in product availability to consumers, and a clear fracture of the North American market for these products. Impacts to price and product availability would have been unpreventable.

FCC, INDUSTRY CITE INSUFFICIENT PROOF

To date, lighting dimmers in North America have been classified as incidental radiators for purposes of electromagnetic interference (EMI), meaning they are not required to be tested and certified to existing harmonized North American EMI Standards. However, the EPS branch insisted that the potential, but rarely observed, EMI from these products in application necessitated harsh action to correct it.

Interestingly, the U.S. Federal Communications Commission (FCC) and industry experiences did not mirror these conclusions. Furthermore, after testing in their own labs, the FCC concluded that there is insufficient proof to warrant changes to regulations or certification requirements (for example, rare instances of interference are best addressed in the field). Even though the FCC shared these conclusions, ISED insisted on proceeding.

NEMA WORKS TO CHANGE PROCESS

When the EPS branch office publishes a new ICES- 005 EMI Standard, the regulation then changes. There is no formal requirement that public engagement take place, and drafts can be made without industry participation or input before they are put out for cursory comment as near-complete versions. NEMA is now working to change this formally, rather than rely on interpersonal relationships to yield fair treatment.

Throughout the past year’s discussions, ISED insisted the changes to ISES-005 were necessary, despite the lack of documented evidence of widespread problems and the clear indication that the change in scope would fracture the market. NEMA and the Electro Federation Canada (EFC) engaged deeply to submit technical and procedural arguments against the scope change, submitting several sets of comments and technical papers. Additionally, the staffs of our two organizations met several times with government personnel from the EPS branch office as well as with public servants at the ministry’s main office.

NEMA engaged contacts in the Office of Management and Budget of the Executive Branch to formally request this topic become a work project for the Regulatory Cooperation Council (RCC), the harmonization body reaffirmed in USMCA.

ISSUE MAY RESURFACE LATER

In the end, all of this attention, along with significant public advocacy, swayed the EPS office to agree to keep wall dimmers out of scope and aligned with the FCC’s treatment for the fifth revision of the Standard. However, the EPS indicates they intend to address this again in the future alongside their repeated calls to adopt international EMI Standards from CISPR in Canada, which NEMA and EFC also have opposed. Our work will continue as U.S. and Canadian industries push for harmonized Standards and to bring ICES-005 into a more public, transparent, and formal review process.

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