Regulatory issues

'''Very few consumers of music gear realize the complex, difficult, ever-changing nature of manufacture of music electronics. Simply putting a circuit-board in a box and offering it for sale is not a viable possibility in the 21st century, due to a lengthy list of factors evolving from government regulations. Not only do nearly all industrialized countries have regulations and court-case precedent covering electrical safety, the issues of RFI (radio-frequency interference) and EMC (electromagnetic compatibility) must be considered. EMC is a major issue for any electronic device sold with a microprocessor inside. And the enactment of ROHS laws by the European Union in 2006 severely restricts the types of materials that a manufacturer can use in an electronic product.'''

Electrical Power And Safety
Many users of music gear have complained about the near-universal use of AC power adapters, or "wall warts", to power devices such as audio processors, small keyboard instruments, and drumboxes in recent years. Until the 1980s, AC adapters were only used to power small devices that could not contain their own power supplies, such as effect pedals. The use of AC adapter external power supplies became more commonplace in the 1990s, partly due to changes in electrical-safety regulations imposed on equipment imported to or made in the EU, and due to subsequent heavier regulation in other countries as a result of the EU's regulations, which influenced legislators in countries such as Australia and Japan. The rise of the product-liability lawsuit in the 1980s as a viable "business", especially in the USA, was also a factor. It encouraged people to sue manufacturers for making "faulty" products that inflicted injury, often whether said injury was due to faulty design, or if it was the result of misuse or abuse of the product by a foolish consumer. Because juries in such cases often found automatically against large companies regardless of the facts of the case, larger firms became very "gun shy" about product safety. Smaller firms followed their lead, simply to try and avoid ruinous lawsuits. The uncertainty of this situation is a powerful motivator, and keeps a number of firms out of consumer electronic manufacturing.

The main issue: bringing AC mains voltages into the product's cabinet. Any electronic device that uses more than one or two watts of power usually must be powered from AC mains. AC mains power varies all over the world, complicating the design of music electronics. In the US, Canada, most of North America, and a few other countries, wall-socket AC mains is (roughly) 120 volts at 60 Hz frequency. In Japan, it is usually 100 volts, at either 50 Hz or 60 Hz (some utilities in Japan use 50 Hz, some 60). In most of Europe, the standard is 220 or 230 volts at 50 Hz. In the UK it is 240v at 50 Hz. The European voltage is very commonplace throughout Europe, Asia, Australasia, and Africa. Some countries, such as Brazil, have failed to standardize. Safety is an important issue with such voltages, as all of them are more than ample to electrocute and kill an adult human, if contacted in the proper way (current discharge via the chest and heart). Wikipedia has a very good article about mains voltages by country, complete with a map.

Also note that the power plugs differ greatly around the world. If only two-wire unearthed power is needed (typical for small appliances), a single 2-pin plug works throughout Europe and in many other countries---the CEE 7/16 "Europlug". If 3 pins are needed for earthing, there are three incompatible standard plugs in the same area of Europe. The most common, the French/German version, is incompatible with the Italian, Swiss, and Scandinavian versions. And there are two different-sized Italian plugs. Australasia and Israel have their own, incompatible plugs and sockets. The American 2-pin plug (NEMA 1-15) and 3-pin plug (NEMA 5-15) are also used in Japan and most of the Americas--usually in countries having 120v power. The old British BS546 plug is still used in India and much of Africa, while the UK itself now uses a totally different plug (BS1363). Argentina uses the Australian plug, but with "line" and "neutral" connections reversed. Some countries, such as China and Brazil, cannot agree on a single standard. Some countries have obsolete plugs in older buildings. Wikipedia has a good overview of different power plugs.



Thanks to Internet dealers, a company selling music gear is prone to end up selling the same gear in many countries, complicating design greatly. There is a proposal to standardize European power outlets, which has apparently failed as of 2011. This nightmare is why manufacturers needing AC mains inside the product have standardized on the "universal" AC mains inlet socket officially called "IEC 60320", and left the procurement of a matching AC mains power cord to the consumer or local dealer. Most modern equipment either has a transformer tap switch that the consumer must adjust for his AC mains voltage, or it contains a "universal" switching power supply that can accept and work on anything from 90v to 264v, with no adjustment.



And for smaller devices, an AC adapter producing low-voltage AC or DC power is almost universal. Most of them are made for 120v or 230v only, and usually can't be adjusted. (Most modern DC-output ones are "universal input", but some are still being sold that are not self-adjusting.) Once again, providing the proper AC adapter is left to the local dealer or to the consumer. If you purchase a product made in another country via a website dealer, you have to be aware of this, and willing to find the proper cable or adapter. Usually it is impossible or very difficult to buy an adapter or power cable for one country in another country.



The moment you feed AC mains into a box, EU regulation EN 60950 of Directive 2006/95/EC, or "Low Voltage Directive For Information Equipment" takes over. It deals with safety in electronic "information" devices powered from AC mains. This regulation is considered to cover music electronics, analog or digital, simply because there is no direct regulation for music gear---sales figures are not sufficient to regulate, and music gear is considered "professional" equipment as opposed to a kind of "home appliance", so music devices are stuck under "information equipment". If it had been considered a "home appliance", a synthesizer would be regulated under EN60335 instead.

The complete list of EU regulations for electrical safety is here. There's a lot of regulations. Most of them are aimed at mass-produced consumer appliances. There's even a regulation for safety in "heated gullies for roof drainage". But there's no mention of music or audio-recording gear.

Because in the 1980s, Japanese companies such as Korg, Roland and Yamaha started to seize the market for music synthesizers, regulators in Europe demanded that those firms start meeting EU regulations for electrical safety. To avoid the high cost of electrical-safety testing and certification by independent testing labs (a requirement in most of the world), these firms started making gear that ran from AC adapters only. The change from analog circuitry to microprocessors at the same time helped to facilitate this, by reducing power consumption and simplifying power supply design.

The United States has no direct federal regulation of electrical safety, but existing laws (and court cases dealing with liability) tend to use Underwriters Labs standards for electrical safety of electronic gear. However, UL standards are quite different from EU standards, making them incompatible in test-lab certification. Getting a product UL certified (usually not by UL itself but by a third-party lab) can easily cost $12,000 or more, and the test does not apply in most other countries. Selling electronics in Canada requires CSA certification, which is roughly similar to UL certification but is different enough to require separate testing. Selling electrical products in Japan requires certification for a PSE mark--again, the tests are different from all others, and require separate testing. Russia, Finland, the UK, China, Korea, and some other countries have similar-but-different safety regulations, requiring different testing. Sometimes they ignore low-production products, sometimes they "crack down"; primarily to put up trade barriers to non-domestic products.

It seems that UL is attempting to "harmonize" its safety standards with the EU standards, under UL 6500. So that, it is alleged, both standards can be tested for at one, for a single price. Supposedly.

One side-effect of all this: the number of certified testing labs has exploded in the last 20 years. Before, there were very few labs, because products tended to be simple and regulations were scarce. Only medical or other safety-critical gear was tested routinely. But the commonplace use of microprocessors, increasing legal controls, import/export regulations, and differences of all the regulations between countries have contributed to a climate of "test everything just in case". So the test labs are making lots of money. And you, the consumer, are paying for it.

There's a bonus nasty waiting for consumers in Asia and some parts of Europe. Many newer buildings have "combo" sockets, which will accept Euro, British, or American NEMA plugs. This is a charming little trick, especially when you consider that all such sockets are wired for the local 220-230v power only. Anyone plugging an American-only 115v appliance into one of these sockets will get an ugly surprise, as the appliance blows up in their face.



How does your modular synthesizer fit into all this? It's usually placed under a "loophole" in the law that many modular cabinet builders unknowingly take advantage of. Because a modular synth could be considered a "kit", requiring some assembly by the end-user, most electrical-safety laws exempt it. If the EU Parliament had tried to regulate electronic kits, they very likely would have killed off the kit industry, and made it almost impossible for hobbyists to obtain components to experiment with. Apparently Doepfer, the world's largest maker of modular synths and cabinets, has been threatened by the German safety authorities over safety testing, in spite of the "kit loophole"; so Doepfer spends some $12,000-15,000 having samples of each new cabinet design tested by an independent lab. This is done only to silence bureaucrats, and has no actual bearing on sales of the cabinets elsewhere in the world. Safety standards in the USA are much less severe, and safety testing is only undertaken by mass-producers or firms wishing to minimize their legal liability. (Or to placate a few local governments, such as the city and county of Los Angeles--which requires "professional equipment" to pass UL safety tests.) Because most people would consider modular synthesizers to be "professional audio" products, requiring some skill and knowledge to use, they have not been subject to the same safety standards that usually apply to home appliances such as TV sets. However, this does not mean such products might not attract a major product-liability lawsuit in the future; the small sales and specialized nature of the modular synth simply make it unlikely. A greedy liability attorney would not pursue a tort claim for injury against a company that grosses less than US$100k/year, simply because he could not be assured of receiving a large fee should he win. Small synth makers are usually sole-proprietor "hobby" firms with almost no financial resources, making them undesirable targets for a tort claim.

RFI and "EMC"
RFI, meaning "radio frequency interference", is a major problem in our world of cellphones and wireless gadgets. US federal law is very specific about electronics being "electromagnetic compatible" with other products. FCC Part 15 testing must be performed on any product having switching frequencies of more than 9 kHz in internal circuitry--including any device using a microprocessor. "Commercial" equipment must meet the Class A standard, while consumer products like small computers have to meet the more stringent Class B standard. A device that radiates a lot of wide-band RF noise, like a microprocessor-based music synth, could interfere with radio communications or broadcasting. Not only could interference cause lawsuits, it could cause criminal liability, by interfering with emergency services and their two-way radio communications.

Testing usually involves an RF-shielded chamber, sometimes an "anechoic" chamber to avoid measurement errors due to acoustic noise. Special antennae, and a spectrum analyzer capable of testing to 4 GHz, are mandatory. This paper (PDF) describes the basic procedure. To make regulators and attorneys happy, it should be conducted by an "approved" testing lab. Such labs are often the same companies that perform electrical-safety certification, and they sometimes offer manufacturers "special pricing" for testing packages. But for a small firm, this testing can still be very costly and difficult to justify for low-production products like synthesizers. FCC Part 15 testing for a single product can easily cost $8,000 or up.

It is possible to perform your own FCC Part 15 tests, by setting up equipment in a rural field, well away from any sources of RF energy. But the test equipment needed is still costly, some knowledge of EMC testing is needed, and the engineer runs the risk of having his tests invalidated in court, because he wasn't "certified". What does "certified" mean? Apparently, it means whatever the FCC and the courts want to say it means. The FCC does not perform actual certification of test labs, they leave it to the "free market", meaning to liability attorneys. So, even setting up a test lab is more an exercise in public relations and maintaining an image of "reliability" and "seriousness" than it is an actual measure of technical ability.

To sell the same product in Europe, IEC 61000 testing is required to certify it for a CE mark. The CE mark simply states that the product has been tested, meets the EU standard, and is legally permitted to be sold in Europe. Needless to say, the IEC test is similar to the FCC Part 15 test, but different enough to make separate testing unavoidable. This typically costs $15,000-$20,000 for each separate product, in the US. The regulation also says that ESD (electrostatic discharge) testing is mandatory, to assure the product will not be damaged by static discharge from the user.

Searching online for information about EMC often leads to the websites of the test labs. Wherein they advertise and brag about their capabilities, but provide very little hard information. Textbooks about RFI/EMC exist but are usually out of print and difficult to find (luckily, some can be found on Google Books). Reading them usually requires some formal education in electronics, including radio propagation and advanced math.

Again, some other countries have their own EMC regulations, test conditions, and certifications. Japan has a similar regulation, also requiring separate testing, but only by a VCCI-registered test lab. I've heard that in Russia, all that's needed to get a GOST-R mark is a suitable bribe. You can test for it outside Russia, then export to Russia with few problems. But a bribe can be far cheaper and easier to do, provided you know who the actual bribe must go to. Similar things happen in countries like Brazil, India and China. Italy is long notorious for having problems with corruption among its customs officials, even for small shipments of commercial goods. And parts of Africa, like Nigeria or Zimbabwe, are an insane nightmare to export to.

So far, modular synthesizers have been too low in production to attract the attention of EMC regulators, in the US, in Japan or in the EU. And the "kit" aspect of a modular synth might serve to invalidate EMC regulations, similarly to electrical-safety standards. However, I have not been able to find court cases that will confirm this. The fact that most modules were analog (containing no RFI-generating microprocessors or other such circuits) in the past has been an advantage, since Part 15 simply doesn't apply to them. With the appearance of DSP-based or microprocessor-based modules in recent years, that could change. A legal challenge to the modular synth has not occurred to date.

Materials
Until recently, electronics manufacturers could use whatever materials they deemed necessary to make their products, and make them reliable and long-lasting. Cadmium is a very toxic metal that was routinely used to plate electronic chassis, because it was corrosion-resistant and could be soldered to. But recent regulations in the US and Europe have banned cadmium in almost all products.

Most electronic solder has been made with the same formula since World War II (and before, in the case of some manufacturers like Kester). Scientists knew that a mixture of 63% tin and 37% lead was the "eutectic mixture", meaning it had the lowest melting point. Since it's difficult to mass-produce solder to such a close standard, most solder manufacturers simply get it as close as possible and call it "60-40" solder. The difference is not critical (claims of some crackpots aside). Tin and lead are the least-costly metals that can be used in a solder, and give very reliable results when used properly, so the 60-40 mixture became the standard for electronics manufacturing. Solders made of bismuth can have a lower melting point, but are more costly and can have problems with reliable "wetting" of a wire or PC-board pad. Indium solders are excellent, but indium is extremely expensive. Solders carrying a high percentage of silver are also costly and are prone to oxidation. So the 60-40 lead-tin solder has been the most reliable, cost-effective mixture for more than 90 years.

Lead does one thing for solder that is still poorly understood today: it helps prevent a bizarre effect called "tin whiskering". For some specialized applications, such as medical equipment or space-rated electronics, manufacturers will attempt to use a pure tin or tin-silver solder, to avoid the toxicity or other problems of lead. Whiskers can sometimes grow between electrical connections, shorting them out.

All well and fine--until 2006, when the EU promulgated the RoHS regulation. Along with banning cadmium plating, hexavalent chromium (also used to plate parts), and certain brominated chemicals that are used to make plastics more fire-resistant, it banned lead solder. Luckily there are a number of exemptions that any maker of modular synthesizers can take, thus avoiding RoHS problems when exporting to Europe. But the maker still has to include an RoHS exemption sheet with every shipment to an EU country. Companies that mass-produce consumer goods, like cellphones, personal computers, appliances and the like, have no recourse but to use lead-free solder.

There are attempts being made by legislators in other countries to outlaw the RoHS substances. The US Congress has considered it, though with no action to date. The State of California will probably outlaw lead solder soon, with other states likely to follow.

60-40 solder is still less costly than any of the more exotic solders being used, and although long-term reliability is still a subject of much argument, 60-40 solder has a proven reliability track record going back to the 1920s. It is not unusual to find an 80-year-old radio whose soldered joints are still solid, shiny, and functional. Since PCs and cellphones tend to be disposed of or die after two years or less, tin whiskering may not be an issue. Only the future will tell.

(E. Barbour, May 2011)