EMC for Semiconductor Manufacturing Facility, Equipment Electromagnetic Compatibility and E33 Directions

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EMC for Semiconductor Manufacturing Facility,
Equipment Electromagnetic Compatibility and E33
Directions

• Industrial Equipment EMC Regulation SEMI E33

Mark Frankfurth, NCE, CLSO Engineering
Manager Product Safety Regulatory
Compliance Cymer Inc. mfrankfurth_at_cymer.com Ph
858-385-6558
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Agenda

• What is Electromagnetic Regulatory Compliance?
• U.S. FCC and Similar Regulations
• The New European EMC Directive
• SEMI E33 Directions and Current Status
• Steps Every Company Should Take to be EMC
  Compliant

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EMC EM Compliance

• EMC ElectroMagnetic Compatibility
• This is the ability of equipment to operate in
  its electromagnetic environment. EMC is a
  performance-based measure.
• EM Compliance is conformance to the rules of
  electromagnetic control regulation.
• This is based on Limits, Standards, Codes,
  Directives, and Laws. Prescriptive measures.
• These are not the same!

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Categories of EM Compliance

• There are a few levels of rigor in EM
  Compliance, these are represented by
• Verification/Self-Declaration
• Industrial equipment
• Certification Authorization
• Consumer electronics, radios, transmitters
• Mission-critical
• Medical, military, etc.

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Approaches to EM Regulation

• There are 2 main courses for EM regulation
  compliance
• U.S. Federal Communications Commission
• Code of Federal Regulations (47 CFR Part 15)
• Emissions only (radiated conducted)
• European EMC Directive
• Directive EU Member Country Legislation
• Emissions Immunity (radiated conducted)
• Part of CE Mark customs enforcement

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Industrial Equipment EM Compliance

• The focus of this presentation is Industrial
  Equipment for the Semiconductor Manufacturing
  Industry.
• This means good news bad news
• Industrial equipment EM regulation is a pretty
  flexible and lenient compliance environment.
• Industrial equipment EM compliance is not well
  understood.

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EM Compliance SEMI E33

• The goal of SEMI E33 revision is to provide EMC
  guidance to the suppliers and users of equipment
  while leveraging existing EM regulatory
  compliance approaches.
• Compliance with the applicable legal EMC
  requirements for the target market will equate to
  conformance with SEMI E33 as currently written.
  

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FCC U.S. Canada

• FCC Federal Communications Commission
• For industrial equipment, typically falling under
  the designation Class A, compliance is pretty
  simple
• Test to ensure emissions are under limits
• Take data to develop a report
• Label the product according to the FCC rules
• File the data/report for later

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FCC Class A Tests Limits

• Class A testing is called verification.
• Methods according to
• Title 47 CFR Part 15
• ANSI C63.4 standard

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The FCC Class A Label Text
The product would be labeled with the following
exact wording

• This device complies with Part 15 of the FCC
  Rules. Operation is subject to the following two
  conditions (1) this device shall not cause
  harmful interference, and (2) this device must
  accept any interference received, including
  interference that may cause undesired operation.

And that is pretty much it for the FCC approach.
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Europe International Markets

• The rest of the globe concerned about EMC
  subscribes to the European approach and
  standards
• EMC Directive Member Country Laws
• Current EMC Directive 89/336/EEC
• New EMC Directive 2004/108
• CISPR, IEC, and EN Technical Standards
• We will concentrate on the New EMC Directive

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The New EMC Directive

• The newly published EMC Directive 2004/108
  resulted from the SLIM and New Approach efforts
  to revise European Directives.
• Published in the Official Journal on 31
  December 2004, this revision of the Directive
  came into force on 20 January 2005. Member
  states must implement it by 20 July 2007.

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New EMC Directive Timeline

• The New EMC Directive was published, entered
  into force, and will take effect as follows

Member Country Implementation Deadline 20 Jan 2007
2004/108 Legislation Published in OJ 31 Dec 2004
2004/108Entry into Force 20 Jan 2005
2004/108 is Mandatory 20 July 2009
2009
89/336/EEC No longer usable to place equipment
on market
89/336/EEC is Repealed 2004/108 is Applied 20
July 2007
89/336/EEC In Effect Until 20 July 2007
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More Background

• The new Directive may be referred to as
  2004/108, Edition 2, or 2nd Edition.
• The 89/336/EEC Directive is in effect until 20
  July 2007 when the old EMC Directive is
  repealed.
• A transition period extends to 20 July 2009
  before exclusive compliance to 2004/108 is
  required.

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More Background

• What is a Directive?
• High-level goals for European Union.
• Instructions for member countries to create
  consistent legislation.
• Hint We are required to follow the laws of the
  countries!
• Cant declare to the new directive yet because
  country legislation is not in place. (e.g. RoHS)

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Interpretations Opinions

• There will be a couple of years of pontificating
  on the meaning of the changes.
• Every interpretation is just an opinion until
• Official European Commission guidance is issued
  or
• Courts rule to set precedents
• Be careful who and what you believe !
• (An updated interpretation Guidance Document
  is expected in late 2006 will it be official?)

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EMC Directive Purpose

• To ensure the function of the Internal European
  Market.
• To ensure and adequate level of electromagnetic
  compatibility among products in the European
  Market.
• Estimated to affect 800 Million products

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New Approach Directives

• State Essential Requirements.
• Are supported by harmonized standards.
• The big presumption Conformance to harmonized
  standards equates to meeting the essential
  requirements.
• Conformity assessment approach is used when these
  boundaries are exceeded.

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Strategy

• As with all regulatory compliance rule changes,
  it is important to study the text of the rules
  and understand the potential impact for your
  products and business.Fortunately, the changes
  to the Directive are not large for most companies
  and appear to be beneficial overall.

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Outside of EMC Directive Scope

• Telecom equipment under RTTED
• Aviation/Aeronautical Products
• Amateur Radio Equipment ITU
• Specificity Clause (Article 4.1)
• Where EMC specified in another Directive
• Example Medical Devices Directive

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Protection Requirements

• Equipment shall be so designed and manufactured,
  having regard to the state of the art, as to
  ensure that
• The electromagnetic disturbance generated does
  not exceed the level above which radio and
  telecommunication equipment or other equipment
  cannot operate as intended.
• It has a level of immunity to the electromagnetic
  disturbance to be expected in its intended use
  which allows it to operate without unacceptable
  degradation of its intended use.

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All in the Definitions

• Equipment apparatus or fixed installation
• Apparatus finished appliance or combination
  thereof made commercially available as a single
  functional unit, intended for the end-user
• Fixed Installation particular combination of
  several types of apparatus and, where applicable,
  other devices, which are assembled, installed,
  and intended to be permanently used at a
  pre-defined location.

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All in the Definitions continued

• Apparatus includes components or subassemblies
  intended for incorporation into apparatus by the
  end-users
• Apparatus also includes Mobile Installations
• Key discrimination factor Apparatus are made
  commercially available to end-users as a single
  functional unit.

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How Does This Apply?

• Large-scale, integrated equipment can
  potentially qualify as a Fixed Installation
• This could prove very beneficial to the shipment
  and installation of leading-edge technology
  demonstration systems where individual elements
  are not yet conforming to the Directive.
• Most equipment will be classified Apparatus.

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Brief List of Changes

• Increased emphasis on Essential Requirements for
  Protection, and good engineering practice
• Competent Bodies no longer exist in the
  Directive. Notified Bodies can be used.
• Independent conformity assessment review of EMC
  compliance documentation is now purely voluntary.
  

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Brief List of Changes continued

• Technical Construction File (TCF) has been
  renamed Technical Documentation that all must
  assemble and make available to provide evidence
  of conformity assessment. A 10 year document
  retention requirement is defined.
• Non-conforming equipment may be displayed or
  demonstrated at exhibits, trade shows, etc.
  provided that
• Markings indicate equipment may not be placed on
  the market until conformity is achieved.
• EM Disturbances from demonstrations are
  controlled.

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Brief List of Changes continued

• Emphasis on testing different equipment
  configurations that could normally occur, or a
  known inclusive worst-case configuration.
• Permanent custom systems are addressed as Fixed
  Installations which we will address further in
  this presentation.
• Definitions have been updated and added to
  clarify terminology and interpretations.

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What is NOT There

• Changes to underlying Standards
• Standards are technology-driven.
• Definitions of Place on the market or Put into
  service as triggers for required conformance.
• This still must come from supplemental
  interpretations e.g. Blue Book. Guidance
  document planned for 2006.
• Onerous cable testing provisions discussed in the
  development of the revision.
• Involvement in Safety of products or systems
• e.g. Functional Safety considerations

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Fixed Installations

• Do Require
• Compliance with Essential Requirements for
  Protection
• Attention to EMC-related installation
  requirements
• Documentation of good engineering practices
• Responsible Person holding the Technical
  Documentation

• Do Not Require
• EMC Assessment
• Declaration of Conformity
• CE Mark Affixed

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EMC Directive vs. WEEE Definitions

• The exception identified in WEEE for Large-scale
  stationary industrial tools appears to have
  little in common with the Fixed Installation
  definition in the New EMC Directive.
• Although elements of the Fixed Installation
  wording could be used to support a WEEE exception
  argument, it does not appear to be a strong case.
  
• Use caution when borrowing definitions!

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Conclusions of 2004/108 Review

• Benefits are provided by New EMC Directive
• Reduced evaluation requirements under TCF Route
• Notified Body oversight is voluntary
• Better coverage of Fixed Installations
• Trade-show provisions
• Improved definitions and descriptions
• Drawbacks
• Potential multiple configuration assessment
  requirement
• Narrow scope of Fixed Installation category

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Coming EMCD Guidance Document

• Contains 60 pages to explain 14 page Directive
• 5 useful Flowcharts for Classification Process
• Presently undergoing refinement by Working Group
• Explanations of each section

• Role of Notified Bodies
• EMC-Benign Equipment
• Areas Where EMCD Not Applicable
• Spare Parts/Repair Activities
• Technical Documentation

• Scope of EMCD
• Essential Requirements
• Rules for Apparatus
• Rules for Fixed Installations
• Enforcement

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Apparatus versus Fixed Installation

• Bad news Almost all products will be
  categorized as apparatus.
• Definitions and interpretations of Fixed
  Installations very narrow, and direction is not
  supportive of Semiconductor Manufacturing
  Equipment (SME).
• Fixed Installations oriented toward
  geographically large systems (railway systems,
  power-plants, etc.) or
• Equipment that is built-into a physical plant,
  e.g. elevators, overhead cranes, communications
  wiring.
• So SME is unlikely to enjoy Fixed Installation
  flexibility.

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Spare Parts Service

• Much like safety guidance, if equipment is
  returned to the original compliant condition then
  no new compliance requirements are triggered.
• If the equipment is changed or upgraded in a way
  that could change the EMC characteristics, the
  equipment must conform to the requirements of the
  New EMC Directive.
• Components subassemblies EMCD provisions apply
  here as well. More explanation is expected in
  this area.

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Conformity Assessment Options

• A flowchart details the potential methods for
  assessing EMC conformance
• Conform to Harmonized Standards
• Detailed Technical EMC Assessment
• Mixed EMC Assessment
• Much more detail expected in this area when the
  Guidance Document is finalized.

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EMC Conformity Assessment Flow
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SEMI E33 Directions

• The SEMI E33 revision seeks to update references
  and overlay semiconductor industry-specific
  information on top of existing EMC compliance
  systems.
• For example, conformance with the processes and
  requirements of the EU EMC Directive is intended
  to satisfy the requirements of SEMI E33.
• The goal of E33 revision is improved information
  awareness of EMC without increased compliance
  requirements for equipment.

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Steps a Company Should Take

• To ensure EMC and EM compliance, the following
  steps are recommended
• Become familiar with the New EMC Directive via
  self-study or available courses.
• Learn pre-compliance methods and test instrument
  usage to improve EMC before the test lab phase.
• Take advantage of EMC expertise when needed to
  resolve problems or interpretation issues.
• Address customer EMC concerns effectively.

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Helpful References Links

• New EMC Directive .pdf
• http//europa.eu.int/eur-lex/lex/LexUriServ/site/e
  n/oj/2004/l_390/l_39020041231en00240037.pdf
• EMCD Guidance Document Preview Article from
  Conformity Magazine
• http//www.conformity.com/0606/0606_F01.html
• Link to Cherry-Clough/Keith Armstrongs Fixed
  Installation Presentation for interesting
  interpretations
• http//www.reo.co.uk/files/kbase/emc2c_Installatio
  ns_under_EMCD2.pdf
• Credits to Isador Straus Gary Fenical for their
  Conformity articles.
• Credit to Dan Hoolihan for his TUV-America New
  EMC Directive slides.
• Credit to Keith Armstrong for his thoughts on
  Functional Safety EMC.

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Author/Presenter Mark Frankfurth

• Mark S. Frankfurth is a graduate of Virginia
  Polytechnic Institute and State University (VPI
  SU "Virginia Tech") in Blacksburg, Virginia,
  receiving a bachelor's degree in Electrical
  Engineering in 1988. Presently holding an
  engineering management position at Cymer Inc.
  overseeing Product Safety Regulatory Compliance
  Engineering, Mark assists in the development of
  high-power industrial laser systems for
  semiconductor industry photolithography
  processes. Background expertise in product
  safety, electromagnetic compatibility (EMC), and
  quality engineering resulted from 5 years as a
  Senior EMC Engineer at AST Research Inc. of
  Irvine, California, where Mark contributed to the
  development of personal computer systems from an
  EMC, safety, and reliability engineering
  perspective. Prior to this Mark participated in
  the development and installation of optical fire
  detection systems detecting UV and IR signatures.
  Mark is a Certified Laser Safety Officer (CLSO)
  by the Laser Institute of America (LIA) Board of
  Laser Safety, a NARTE certified EMC Engineer, and
  formerly was an ASQ Certified Quality Engineer.
  A member of IEEE for 20 years, Mark has served in
  Chapter and Section officer roles including San
  Diego EMC Chapter Chairman and Section Secretary.
  Organizations Mark supports as officer or member
  include SESHA, ASSE, NFPA, SEMI, NARTE, and IEEE.
  Mark is continuing his professional development
  by pursuing a professional certificate in
  Occupational Health Safety and Certified Safety
  Professional credentials. Contact Info email
  mfrankfurth_at_cymer.com phone [phone]