General: Products categorized as “IoT” (Internet of Things) consist of two main elements

  • An “Appliance”, which is the smart device and

  • The “App”, which is the software that runs on a PC, tablet, or smartphone that is specific to operating the appliance.

These products have additional considerations for safety and performance due to design
features necessary to accomplish wireless communication and remote operation of
devices.

Product Safety of IoT – the Appliance: It is already common if not expected that these
types of products are certified to UL, CSA, and similar product safety standards when
sold around the world. However, the compliance design process for some electronic
products manufacturers can be greatly impacted by adding these new/popular product
features. This includes:

  1. New Circuit Classifications: Adding intelligence to Home Appliances involves adding
    “secondary circuits” to a product. Something as simple as a USB port causes the
    need for creating a Safety Extra Low Voltage circuit (SELV). SELV circuits require
    isolation devices meeting double or reinforced insulation requirements. Additional
    electrical spacings, increased product cost, and more complicated manufacturing
    processes.
  2. Remote/Unattended Operation: Adding remote/automated operation to a product
    increases the risk that if something goes wrong with the appliance, it will not be
    detected by the user. That can increase the number and type of fault conditions
    applied to the product during the certification testing process. These tests are
    focused at looking for a fire hazard that could be magnified due to unattended
    operation and the inability for user intervention.

  3. EMC & Immunity Testing: For many basic appliances, EMC/Immunity does not
    apply. However, adding IoT capability to a product means adding microprocessor
    based circuits and switching power supplies to power them. These components
    operate in a manner that causes the IoT appliance to have to comply with EMC
    requirements in North America and EMC/Immunity requirement in the European
    Union. Suddenly the compliance process can be much more difficult and expensive.
    Radiated emissions compliance can be difficult, especially for products with a plastic
    enclosure. Immunity testing includes subjecting the appliance to a wide variety of
    electrical phenomenon including ESD to user interfaces (electro-static discharge)
    and Transients on all ports.

  4. Safety Standard Considerations: The development of IoT has been much faster than
    the typical timeline for a safety standard update. Consequently, another
    consideration is the specific safety standard(s) with which your product is evaluated
    – do the safety standards that you use contain the most up to date circuit
    requirements covering IoT type circuits? Electronic product standards harmonized to
    IEC standards have well written requirements for the types of circuits associated
    with adding “smart” features. However, there are several North American home
    appliance standards that are not “internationally harmonized”, which can make it
    more difficult to design a compliant IoT product.

Product Safety of IoT – the App: The primary objective of most IoT is the ability to
monitor data and remotely control a device from a smartphone (or PC). In order to
facilitate control, a product specific “App” (IoT software) is installed in the smartphone. As
much as we count on the internet and access to the internet through wireless
communication devices, several elements of the overall system lack the reliability
necessary for safety control of products. Consequently, smart appliances must
incorporate compliance design considerations to prevent hazards caused by problems
with the App and in communicating with the App. This includes:

  1. Software Safety & Reliability: For products that have safety critical features that are
    provided by embedded software, a software safety review can be performed to verify
    reliability of the software. However, when the software is run on a remote device
    from which a communication link cannot be guaranteed, the App simply cannot be
    relied upon for safety. Performing a software safety review on an App cannot
    overcome the inherent problems with internet connectivity. The product must be
    designed to “fail safe” in the event of lost communication with the App.
  2. Fault Conditions: Additional App related fault conditions to consider include
    unexpected activation – if we can sit on our phone and accidentally make a call, the
    same process can happen with an App, turning “on” or “off” an IoT appliance without
    the awareness of the user. And of course, don’t let a hacker cause havoc with your
    product. A wide variety of problems could be caused by an unscrupulous hacker
    who invades your IoT appliance operating system. Serious safety hazards could be
    caused including turning on/off an unprepared appliance, or causing the appliance to
    speed up or slow down leading to overheating or mechanical failure. In a worst case
    scenario, your customer is sitting near your product when a hacker makes it to turn
    on unexpectedly, causing an injury to the user or damage to property.

YES, there is a lot to consider!

CertifiGroup can Test & Certify your IoT Products
Compliance Assistance Services to help you get it right the 1
st time
Preliminary Design Reviews, Design Guidance, Training
US, Canadian, CE, & International Certifications

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