Below Follows Text Taken from Doc 10-615/R0

July, 2010 IEEE P802.15-10-0xxx-00-0007

IEEE 802.15

Wireless Personal Area Networks

Project / IEEE 802.15 Working Group for Wireless Personal Area Networks
Title / Suggestions for improving doc 10-615/r0
Date Submitted / 10th September14th July,2010
Source / Joachim W. Walewski /
Re: / LB57 Comment Resolution
Abstract / This contribution constitutes the supporting text promised in CID E-372 in doc 10-0681/r2. In this text I suggest how to improve text in doc 10-615/r0 (regulatory whitepaper). These suggestion include edits (as highlighted by “track change” and technical/editorial comments on the text (right margin)…
Purpose / This document is intent to resolve a LB57 comment related to bibliography element [B44]
Notice / This document has been prepared to assist the IEEE 802.15. It is offered as a basis for discussion and is not binding on the contributing individual(s) or organization(s). The material in this document is subject to change in form and content after further study. The contributor(s) reserve(s) the right to add, amend or withdraw material contained herein.
Release / The contributor acknowledges and accepts that this contribution becomes the property of IEEE and may be made publicly available by 802.15.

Below follows text taken from doc 10-615/r0.

The regulations are included in this white paper relate to standard IEEE 802.15.7, which addresses standardization for visible- light communications (VLC). In this whitepaper we and provide insight into Green GrowthITC, safety requirements, frequency spectrum, and notional regulations pertaining LEDs.

Requirement for Safety, Spectrum Frequency, and National Specific LED Regulations.

1.Green ITC Growth

There are some regulations related to promoting VLC promotions. VLC has a good chance potential to createnew marketsaccording related to the energy scarcitycrisis factor, global climate changes, environmental problems, and lack of radio resources.

The Kyoto Protocol is a protocol related to the international Framework Convention on Climate Change with the objective of reducing greenhouse gases that cause climate change.As of January 2008, and running through 2012, some 170 several countriess (170)have are required to reduce their greenhouse gas emissions by a collective average of 5% below their 1990 levels.[ 1]

RoHS(Restriction of Hazardous Substances Directive, 6HS) specification restricts the use of material Mercury in products, which is used influorescent lamps. [ 2]

LED is also a better option for waste treatment thanFluorescent lamp in terms of WEEE(Waste Electrical and Electronic Equipment Directive).[ 3]

2.SRequirement for Safety requirements

2.1 Flicker

Light flicker is defined as the variation of a light stimulus that results in detectable physiological changes in humans. There are requirements for safety related to regulation.

The PHY modulation of light sources for Visible Light CommunicationVLC shall be providedrequire a non-flickering mechanism. The light Light flicker can have harmful health impacts on humans/animals.[ 4] A l ight flicker is an impression of unsteadiness of visual sensation induced by a light stimulus whose luminance or spectral distribution fluctuates with time.

LRegulations of light flicker is regulated in standard are:

IEC 1000-3-3/EN 61000-3-3: Electromagnetic compatibility. Part 3: Limits – Sect. 3:Limitation of voltage fluctuations and flicker in low-voltage power supplysystems for equipment with rated current < 16 A. 1994

IEC 1000-3-5: Electromagnetic compatibility. Part 3: Limits – Sect. 5: Limitation ofvoltage fluctuations and flicker in low-voltage power supply systems forequipment with rated current greater than 16 A. 1994

[ 5]

2.2 Radiation safety

Regulations pertaining radiation safety of lasers are:

IEC 60825-1: Laser safety[ 6]



ANSI Z136: Laser Safety Standards - ANSI

[ 7]EN 207: European norm for laser safety eyewear.

According to the IEC regulation Tthere are safety classes 1, 1M, 2, 2M, 3R, 3B, and 4 for commercial products. Class 1 laser is safe under all conditions of normal use.

Regulations concerning incoherent emitters of visible light strength in standard are:

IEC 62471: new lamp safety[ 8]



LEDs used as lamps would have to be assessed and classified according to the new lamp safety standard IEC 62471. In terms of this standard, even the relaxed requirements for GLS-sources (General Lighting Service) can be applied. Thus, the lighting part of the technique will definitely be covered by the lamp safety standard IEC 62471. According to existing safety standards, the durations without modulation would have to be addressed by IEC 62471, while the very same LED would have to adhere to IEC 60825-12 during data transmission.[ 9]

3.Spectrum Frequency

Spectrum licenses are is generally regulated in agreed as an intergovernmental treatiesy text. The spectrum under consideration covers 3 Hz to 300 GHz.[ 10]There are two main communication spectrum licenses: a broadcasting licensing and a cellular licensing. There is also special Non License spectrum such as ISM (Industrial, Scientific and Medical). [ 11]The spectrum of VLC (is 370 THz – 870 THz) has not yet been regulated in terms of wireless data communication.which is beyond one which is agreed under inter government regulations. Thus, VLCVLC doesn’t need any spectrum licensing.

4.Region-specific regulations

3.1.4.1.European Union

The regulators in EU have a directiveremit only to regulate frequencies below 3,000GHz.

With no recommendations existing currentlyat the minute for VLC, there is of course no pan-European legislation.

Market access is thus governed by the remaining relevant directives, viz. of which Ssafety and electro-magnetic compatibility (EMC)EMC apply. Both are well understood and defined and should present no surprises for manufacturers. Safety is defined by EN60950[ 12].EMC is ascertained according to product will be defined by Product type. If no product specifications are available, default generic emission and immunity standards do will apply.yRESOLUTION 955 (WRC‑07) is related to consideration of procedures for free-space optical links at the World Radio communication Conference (Geneva, 2007).The items to note are

that frequencies above 3,000GHz are already used for various optical applications from telecommunication links to satellite remote sensing;

that optical links are currently under consideration by several ITU‑R Study Groups;

that Recommendations ITU‑RP.1621, P.1622, S.1590, RA.1630; SA.1742, SA.1805, and RS.1744[ 13][ 14]contain information pertaining to free-space optical links and remote sensing;

that the ITU‑R is in the process of preparing reports regarding the possibility and relevance of including in the Radio Regulations frequency bands above 3,000GHz as well as fixed service applications using such frequency bands,

that Resolution118 (Marrakesh, 2002) of the Plenipotentiary Conference instructs the Director of the BR to report to world radio communication conferences on the progress of ITU‑R studies concerning the use of frequencies above 3,000GHz;

that the ITU‑R has identified technical aspects regarding the use of optical free-space telecommunications as an item requiring urgent study by the ITU‑R Study Groups

There are resolves resolutions to consider possible procedures for free-space optical links, taking into account the results of ITU-R studies covering at least sharing aspects with other services[ 15], . Aa clear definition of the band limits and measures needs to be considered if allocations to various services in the Radio Regulations above 3,000GHz are considered to be made feasible., invites ITU-R to conduct the necessary studies in time for consideration by WRC 11.

3.2.Japan

3.3.4.2.

The Change in Japan’s Energy Saving Law in April, 2009 is focused on the energy saving in the office/household section, which has been increasing at 1.4 foldtimes between 1990 and 2005 (the largest increase in energy consumption).There are neededis need tostrengthen furtherimprove the energy savings especially in the office/household sectorion (offices /and convenient stores as well as houses/buildings).

One The energy unit for companiesin the past only consideredwasfactoriesa company unit including factories only before. [ 16]From April, the company unit includes not only factories, but also offices (including head office and sales offices, etc).[ 17]Commercial entities consuming more thanThe unit using energy more than1,500 KL[ 18] annually need s to be reported their energy usage to the to Japanese government.

In order to construct a large house/building (more than 2,000 m2 ㎡), the owner needs to report its energy saving plan to Japanese government. The sales agent of houses/buildings needs to introduce the efficient energy saving methods.[ 19] The energy saving methods needs to be explicitly indicated.

It is one of the features of LED that power consumption is less than the incandescent lamp or the fluorescent lamp[ 20]. The power consumption of LED is about 1/10 of that of incandescent lamp[ 21] and about 1/2 of that of fluorescent lamp[ 22]. Given the current worldwide energy mix, this reduction in consumed electrical power Moreover, it leads to a reduction in carbon dioxide (CO2) emissionreduction because LED lighting consumes power less than other lighting.

In Japan, “Electrical Appliance and Material Safety Law” known as PSE (Product Safety, Electrical Appliance & Materials), which is the law that providesed the technological standard related to the safety of electrical appliances, . The law was enforced in April 2001. As of this law non-compliant

After “Electrical Appliances and Materials Safety Law” is was enforced in April 2001,products the product that has not suited implemented the lawcannot longeris supposed not to be sold in Japan.

The PSE is related to “Specified Electrical Appliance and Material.” This includes appliances such as AC adaptors, vending machines, Electric massage machine, electric toilet seats, etc. The amount of items considered infor the[ 23] PSE is 115 (as of December 2007). “Electrical Appliance and Material except Specified Electrical Appliance and Material.” also includes appliances such as lamps, fluorescent lamps, refrigerators, vacuum cleaners, electric washing machines, etc. The numberamount of items considered at that time wais 339.

The dDifference between the two PSEsis relateds to theis level of applied safety. To put it briefly, the risk posed by appliances in of “Specified Electrical Appliance and Material” is higher than “Electrical Appliance and Material except Specified Electrical Appliance and Material.” Therefore, a maker of “Specified Electrical Appliance and Material” must pass the adaptability inspection for safety by the registration inspecting agency. On the other hand, a maker of “Electrical Appliance and Material except Specified Electrical Appliance and Material” ensuresinspects the adaptability for safety by a maker itselfof the product herself or himself.

PSE also appliesd to a desk lamps using that used uses LEDs, LED lighting system, etc. On the other hand, it does not apply to LED lighting itself such as a LED lamps, LED fluorescent lamp (as of September 2009). [ 24]Therefore, a LED lighting maker does not have tois not required to inspect the adaptability for safety. [ 25]But LED lighting maker should do submit to voluntary inspection,to improve consumer concerns.[ 26]because a customer feels relieved by doing so.

3.4.Korea

3.5.4.3.

There is currently not ano VLC rRegulation in Koreasincedue totheJustcommunications start up technology and beyond frequency spectrum 3,000 GHz has not been considered until recently.are just started to be under consideration.The LED- related regulations are LED Lamps for safety and EMC(Electromagnetic compatibility).[ 27]LED Lamp rRegulationsare pertain toinclude LED traffic signals, LED headleading lamps, LED lamps with AC/DC converter. The goal of LED regulation is an energy saving and, an electrical safety. Measurement itemsable quantities addressedinby regulation are luminous intensity, luminous- intensity stability, and chromaticity.

In 2008 the government of Koreagovernment announced in 2008 a Green Growth with LED Promotion 1530 project[ 28]. The target of the 1530 project has the plan thatis toreplace[ 29]s30% of all traditional lamp[ 30]swith LED lamps up to 30% ratio by year by 2015 and thus reducing the overall . The goal of the project is for the reduction of the electrical power consumption. We will notThere will not be any use of incandescent lamps (electric bulb) Lamp after 2013 in Korea.

Korea Regulations related to lamp are as same theas following IEC documents;

IEC 60050 - International Electro Technical Vocabulary [ 31]

IEC 60061 - Lamp caps and holders

IEC 60360 - the standard method of measurement of lamp cap temperature

IEC 60695-2-1-1 - Fire hazard testing

IEC 61000-3-2 - Electromagnetic compatibility (EMC)

IEC 61347-2-13 - Lamp control gear

IEC 61547 - lighting equipment which is within the scope of IEC technical committee 34, such as lamps, auxiliaries and luminaries, intended either for connecting to a low voltage electricity supply or for battery operation.

IEC 62384 - DC or AC supplied to electronic control gear for LED modules - Performance requirements

[ 32]There are notis noan eye/skin safety rRegulationsin Korea[ 33]. Spectrum fFrequencyregulations consideration cover the electromagnetic spectrum froms9 kHz to 300 GHz in Korea and do thus not affect VLC.

4.4USA

4.54.4

LEDs have received a lot of attention in recent years primarily due to its promise of being a replacement to the more traditional illumination methods (incandescent and fluorescent) due to its lower energy consumption. [ 34]Energy use and its management has become a national priority in the U.S., [ 35]and according to the National Institute of Standards and Technology (NIST), lighting accounts for 8% of the total national energy usage. Therefore, LED- based lighting certainly is expectedstands to play an important role in reducing the energy usage. Apart from state level, county level, and city level regulations that govern the display of large LED signage, there are few national level regulations that govern the use of LEDs and LED systems. [ 36]There are, however, specific international regulations that cover lamps and lamp systems (including LEDs) which must be met. [ 37]The two main standards that are relevant to VLC systems are the following optical radiation safety standards: (1) l Lamp- safety standard IEC 62471, and (2) lLaser- safety standard IEC 60825-12. Below we will briefly outline the two standards along with additional information on LEDs that may be useful.

FThe free- space optical communications usage is covered by the lLaser- safety standards IEC 60825 series, primarily the IEC 60825-12. Non-laser applications are generally covered by, and rest of the applications are mostly covered by the Llamp- safety standard IEC 62471. The IEC 62471 which covers lamps and lamp systems operating in the 200 nm to 3000 nm wavelength range. This standard also covers pulsed lighting sources such as fluorescent lighting as well as LED dimming by use of using pulse- width modulation., which implies that it covers both lighting and communication uses of LEDs. The Laser safety standard, IEC 60825-12 regulates free space optical communication, and it specifically includes LED based systems even though LEDs radiate at a much lower levels than Lasers. Thus, in a VLC system two different safety standards are applicable depending on whether the system is used for lighting only or lighting plus communications. [ 38] Until this paradoxical situation is resolved, VLC systems must comply with both the standards.[ 39]

Another relevant standard to be considered is the IEC 61000-3-2 and IEC 61000-3-3 for harmonic emissions and flicker where all lighting products fall under Class C. ANSI lighting standard also covers harmonic emissions. [ 40]

All lighting products sold in the United States are subject to industry standards governing safety and performance. Standards are important to ensure that products will have high quality and their performance will be specified uniformly for commerce and trade. Several standards have been developed fairly recently that detail the color specifications of LED lamps and LED light fixtures, and the test methods that manufacturers should use when testing these solid state lighting products for total light output, energy consumption and chromaticity, or color quality.

[ 41]Clarifications to the existing standards and/or new standards relevant to VLC may be developed, and we will update this document as appropriate.

The Energy Information and Security Act of 2007 began the process of restricting the sale of inefficient lamps in the US.

NIST is working with the U.S. Department of Energy (DOE) to support its goal of developing and introducing solid-state lighting to reduce energy consumption for lighting by 50 percent by the year 2025. The department predicts that phasing in solid-state lighting over the next 20 years could save more than $ 280 billion in 2007 dollars.

The Illuminating Engineering Society of North America (IESNA) published a documentary standard LM-79, which describes the methods for testing solid-state lighting products for their light output (lumens), energy efficiency (lumens per watt) and chromaticity, and LM-80 for lifetime, or lumen depreciation. The American National Standards Institute (ANSI) standard C78.377-2008 specifies the recommended color ranges for solid state lighting products using cool to warm white LEDs with various correlated color temperatures.