April
2011
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Spring 2011 Newsletter |
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In this issue:
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ENERGY STAR® Program Takes Off |
The EPA’s ENERGY STAR® program has leapt out of
the starting gate, providing
Certification to several thousand products in the
first months of operation, ranging from geothermal
heat pumps to computers and refrigerators.
Approximately 1000 of these devices are in the home
appliance and IT sector. The program is expected to
grow rapidly, as more manufacturers submit
applications to qualified Certification Bodies (CBs).
The certification program was launched by
the EPA last year in response to increased scrutiny
of voluntary programs by the Inspector General at the
EPA and the Department of Energy. The team at EPA
went into full gear to develop an ISO Guide 65-based
system of Certification and designated Accreditation
Bodies to accredit Certification organizations.
In addition, the ENERGY STAR® program requires the
use of Accredited Test Laboratories for the
reporting. Manufacturers can provide test data under
a witnessed or supervisory program. Once the product
has been found to be acceptable, the CB uploads the
information to an EPA database for creation of
qualified product lists.
Post-market
surveillance is a critical part of this program (as
with most Certification programs). Yearly
surveillance will be carried out on 10% of devices
certified, according to the mix of categories that
the CB approves. In addition, recognizing that
competitors may wish to challenge the veracity of
other manufacturers’ devices, a “Challenge” may be
issued; this would result in a re-test of the product
by a third-party laboratory.
Very fine details
are being hammered out, including the effect of
various model variations on the energy consumption
profile of the device. Several categories of devices
have evolving requirements, including newly-revised
requirements that have recently been issued for
Televisions, Set-Top and Cable Boxes (STBs).
Washington Laboratories Ltd. received accreditation
to test under the ENERGY STAR® program on April 1,
2011. No Joke. For more information, contact
EnergyStar@wll.com or Steve Koster at 301
216-1500.
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ACIL Mid-Winter Meeting Recap
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The
2011 American Council of Independent Laboratories
(ACIL) meeting was held in Arlington Virginia on
March 29th, followed by a visit to the US Trade
Representative (USTR) the following day. A summary
of the topics is presented herein.
NIST Reorganization. The National Institute
of Standards and Technology has recently been
re-organized to streamline its operations and align
the laboratory functions along mission-based lines.
The reorganization, under Director Patrick Gallagher
is proceeding apace; however, the principle
objectives for the organization haven’t changed.
Critical to US Export Initiatives are ongoing
Standards In Trade (SIT) programs that bridge
international standards organizations in developing
parts of the world with US regulatory, testing and
standards interests.
Conformity
Assessment Meeting It was standing room
only at the Conformity Assessment Section meeting.
We enjoyed a full plate of CAS delights, including
domestic and international regulatory updates,
laboratory accreditation processes, new device
approval processes and a detailed review of
proficiency testing, which is required to
demonstrate ongoing competence.
The featured
speakers included: Joghindar Dhillon from NIST,
DeWane Ray from the CPSC Office of Hazard
Identification and Reduction, Eamon Monahan from the
EPA ENERGY STAR program, Peter Lefkin from the IEEE
Conformity Assessment Program (ICAP), Elise Owen
from the American National Standards Institute
(ANSI), Luis Hernandez and Rodrigo Jimenez from
Mexico’s Asociación Nacional de Normalización y
Certificación del Sector Eléctrico (ANCE), George
Tannahil from the FCC, Ira Keltz from the FCC,
Mitchell Lazarus from Fletcher, Heald and Hildreth,
Harry Hodes from Acme Testing Company and Mike
Violette from Washington Labs.
US
Trade Representative Office Visit.
Representatives from ACIL and its membership
visited the USTR office on March 30 to discuss
China. The trade issues with China are well-known
and popular in the news media. The one-sidedness of
the US-China trade picture, however, has an arcane,
but significant effect on fair exchange of many
goods. Basically, Chinese manufacturers are able to
avail themselves of a totally open product approvals
process; that is, there are many private-sector
laboratories that operate in a competitive space to
provide product testing to US (and international)
standards.
Hence, a manufacturer in China has
more than 90 labs to choose from, all over the
country. Importers to China, however, have to pass
through the proverbial “eye of the needle” to get
devices approved to the Chinese specifications. That
is, there is only one route, and that is through
accredited China government labs.
This
restriction (even after 10 years of acceding to the
World Trade Organization (WTO)), is a significant
and discrete barrier to trade. The Chinese
accreditation authority, China National
Accreditation Service for Conformity Assessment
(CNAS) signed (in 2000) an agreement called the
International Laboratory Accreditation Cooperation
(ILAC) Mutual Recognition Agreement (MLA) for
Testing and Calibration. Under current policy,
however, foreign entities cannot be accepted to test
for domestic product approvals, even though many of
the technical standards are harmonized.
Until
this barrier is struck down, US exporters will
continue to be at a disadvantage.
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Japan Certification for Wireless Devices
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Implementation of The US-Japan MRA Aids
US
Manufacturers
A
bright spot in
the
US-Asia trade picture is the
newly-adopted certification program that allows US
entities to certify radio devices for the Japanese
market.
 Our sister company, American Certification
Body, Inc. (ACB) has been approved in the first
round of Certification Bodies recognized to perform
Certification for wireless devices to Japanese Radio
Law, increasing market-access for manufacturers on
both sides of the Pacific.
Under a bi-lateral
agreement, the US and Japan have effected the
implementation of a Mutual Recognition Arrangement
that allows the acceptance of certification
decisions under each respective country’s
regulations. This new arrangement offers more
options for device manufacturers.
Prior to
the agreement, it was necessary to test and certify
products in Japan. This new recognition allows US
manufacturers to choose a local testing facility,
submit locally and gain approval in the US for the
Japanese market . “This is a great boon to our
clients, especially given the global nature of the
high-technology market,” says Dennis Ward, Director
of Engineering for ACB.
To obtain an
approval, one must generate a report and demonstrate
conformance (and submit to a Certification Body). To
determine what data must be collected, it is
necessary to refer to the ordnances that cover the
specified equipment, notably the “Ordinance
concerning Technical Regulations Conformity
Certification of Specified Radio Equipment (aka
Ordinance of the Ministry of Posts and
Telecommunications No. 37, 1981).” This document
lays out the various types of equipment and what
data needs to be collected and what instrument is
used to collect the data.
This process is the
end-result of a public-private partnership and
commitment; a commitment that improves the trade and
good relationship between the US and Japan, now more
important than ever. NIST and the FCC partnered with
their counterparts in Japan at the MIC to develop
the criteria for mutual acceptance. On the private
side in the US, ANSI and ANSI-ASQ National
Accreditation Board (ANAB) provided the necessary
accreditations. On the private side in Japan, DSP
Research led invaluable technical liaison and
fostered communications amongst the various
partners.
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Nuclear Power Engineering Advances on
Tip-Toes
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Safety of nuclear power plants is in the eye of the
media and technical storm after the devastating dual
disasters in Japan last month. Much of the
engineering that is designed into these plants are
state-of-the-art and in our view the nuclear industry
has built multiple-redundant systems in the plants
where we have worked.
But Mother Nature always
holds the trump card.
In the US, to license a
plant, the Nuclear Regulatory Commission (NRC)
mandates compliance with Title 10 of the Code of
Federal Regulations (10 CFR). A variety of testing is
mandated for safety-critical systems.
To commission an electronic system—or an upgrade
to a system—one must be compliance to the NRC Reg
Guide 1.180. This guide covers electromagnetic
emissions and susceptibility of equipment and calls
for subjecting electronics systems to a wide range of
simulated EM sources. For our part, EMC tests include
a wide array of methods that are well-known in the
industry, many of the test methods having been
employed for military and commercial systems for 30
years or more. The limits and levels that are tested
to have worked reasonably well under “normal”
conditions. Plant Life Extension or PLF is a big deal
in the nuke industry as operators want to incorporate
upgrades to extend the operating lives of some of the
plants past the initial 40 years of licensing.
On the mechanical side, seismic testing is a
critical part of plant and equipment design. At the
Fukushima Daiichi plant, the systems were subject to
vibration testing that simulated a magnitude 7.9
earthquake. The magnitude 8.9 earthquake that did
occur represents an amplitude difference of 10 times
the designed level. (the Richter scale is a base-10
logarithm metric). The energy released follows a 3/2
scaling, so a difference of 1.0 in magnitude
corresponds to an energy release of 31.6 times.
Under-specifying can have disastrous results.
In the wake of the Japan disaster, the NRC
released an updated “fact sheet” on
NRC’s seismic vulnerability assessment.
This leads to a discussion of the nature of
specifying engineering margins. The NRC and nuclear
industry employ statistical methods of
Probabilistic Risk Analysis (PRA) to
determine “how safe is safe enough?”
An
analysis takes a distinct path: First, a
hazard is specified. The “worst-case”
outcome in a nuclear accident is damage to the core;
loss of cooling water being the principal problem.
Next, initiating events are
determined (loss of cooling water by damage sustained
to pipes or, in the case of Fukushima Daiichi, the
loss of electricity to power the pumps and/or damage
to the pumps from the tsunami).
The next
question is: frequency of occurrence.
Hmm. Catastrophic events are usually
chains-of-events, with many different
branching possibilities that must be
examined. This complicates the analysis.
In
the forty or so years of the nuclear industry, PRA
methods have evolved and (hopefully) uncertainty
margins in the analyses have been tightened. In our
work, there is reference to “Three Mile Island
Modifications” or “TMI Mods”. These engineering
changes to system design—often performed during plant
re-fueling shutdowns—are supposed to mitigate the
chain of events that caused the partial core meltdown
at the Pennsylvania plant in March 1979.
It
will be interesting to see if “Fukushima Mods” get
built into next-generation nuclear plant designs or
upgrades made to existing plants. Naturally,
increased scrutiny to seismic specifications is
underway at regulatory bodies and utilities all over
the world. For the tsunami hazards, there are
inherent vulnerabilities at many plants that have
been built near the ocean. The San Onofre Nuclear
Generating Station (SONGS) is a stone’s throw away
from the Pacific Ocean and uses seawater in its
secondary loops for cooling; its two active reactors
provide just over 2.3 GW of electricity for Southern
California. On the other side of the continent,
Calvert Cliffs Nuclear Power Plant (CCNPP) sits a few
meters above the waters of the Chesapeake Bay.
What is the likelihood of a big wave hitting the
coast of SoCal and makes one wonders how high a wall
is high enough? And to the long-term implications of
sea level rise, what barriers might be needed in the
next 60 years to protect CCNPP?
Living in a
probabilistic universe, one may never know until a
next “big event” makes the engineering community
scratch their collective scalps and wonder: Who Knew?
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Burying (and Re-burying) the Dead in Mỹ Tho,
Vietnam
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Despite the rapid urbanization
and influx of Western thought, there are still
strong traditions not far from the shops
featuring Chanel and Burberry in Central Saigon.
During our trip just before the rainy
season, we were escorted to the Mekong River
Delta by a convivial forty-something named Tran
Thanh. “Call me Mervin,” he said from the front
seat of the new Toyota SUV as we pulled away
from the Rex Hotel.
We exited the center
of District 1 and hopped on the 40 kilometer
divided highway to Mỹ Tho.
Mervin? Why Mervin?
“An English
tourist gave me the name a few years ago. He
said ‘you look like a Mervin.’ What do you
think? I think it’s a popular name, yes?”
We shook our collective heads; can’t say
that we know too many Mervins—maybe it’s a
British thing. We now know one in Saigon,
anyway.
“We are going to Mỹ Tho. Forty
minutes. Very fast.”
The new Highway 1,
built by the Japanese and completed in the last
year, cuts the drive time by a full hour between
the metropolis of HCMC and the rural river area
southwest of the city. We zipped along at a neat
80 kph into the fertile farming areas where the
muddy Mekong feeds the farming and fishing
industries.
“Look. Over there.” He
motioned out the window to a quilt of rice
paddies. “You see the tombs?” Here and there
groupings of colorful sarcophagi were raised on
platforms above the level of the flooded fields.
“Farmers want to be buried with the land. They
want it to stay in the family a long time, so
they build the tomb right in the field.” He
paused and turned around in his seat and looked
at us. “In the village, you will see, they bury
the dead right next to the house. Either way,
they want to make it so new people don’t change
the land.”
Or want to move into the
house, apparently.
“You know, this area
was very busy during the war. My uncle fought
with the north. He died when I was eight.” Thanh
turned and faced forward for a few moments and
said something to the driver, Mr. Dao.
Thanh’s uncle was among the thousands of
Vietnamese missing-in-action that were absorbed
back into the Earth during the war.
“My
uncle was Việt cộng.” Thanh said,
matter-of-factly. “My father wanted to find his
body and bury it, so he went to a local
fortune-teller.”
“The fortune teller drew
a map where we would find his bones.” Did it
work?
Thanh was silent a moment and
turned back to face us. “Yes, of course,” he
replied without reserve. “We asked the fortune
teller how we can know if it was the right
place. He said: Take a chicken egg and balance
it on a chopstick. If it does not fall, you are
in the right place.”
Hmm, hard enough
under the best of conditions.
“And
although it was very windy, the egg stayed on
the chopstick. We dug and found my uncle’s
bones.”
And you brought them home.
“Yes, we brought them home and buried them
next to my grandmother’s house. She was very
happy. And you know what?”
What?
“She died the next day.” He
paused and smiled sadly. “She was waiting for
her son to come home, I think.”
Thanh, we
asked: what about the custom of re-burying the
dead?
“Yes, we do that. After three
years in the ground, the bones are dug up and
washed with rice wine. Then we bury the bones
for a ‘happy burial’ with the other family. It
must be done at night-time.”
What a job.
“There are special workers who do this. For
my grandmother, we hired the son of the same
fortune-teller. The family is expert in the
dead.”
A new meaning to ‘The Family
Business’.
“We came to the graveyard at
four a.m. It was very dark.” Thanh laughed and
added: “And a little scary! I couldn’t do that
kind of work!”
Me either.
“He dug
up her bones and washed each one with the rice
wine and wrapped with paper and put in a small
box. We put her in the family tomb in the field,
next to her husband and parents.” He tapped the
driver Dao on the hand and gestured for him to
turn right; we passed through Ben Tranh, one of
a million bustling and chaotic road-crossings in
this land of many wonders.
“Now they are all together. It’s good,
right?”
Thanh/Mervin smiled.
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