D of C for *component* power supply to LVD, where the specified presumption of
conformity is 60601-x report.

D of C for power source that can be used as separate device (not necessarily
incorporated into end-use equipment) to MDD where the unit meets all
requirements for intended usage in accordance with all applicable 60601-x.

I feel that we get too worked up about DofCs for components. The important
docs for components are the test standard and the test report.

Brian 

 > -----Original Message-----
 > From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of
 > pat.law...@slpower.com
 > Sent: Tuesday, January 12, 2010 9:14 AM
 > To: emc-p...@ieee.org
 > Subject: External power supplies covered under Medical 
 > Device Directive?
 > 
 > Good morning,
 > 
 > I'm having a discussion with a co-worker concerning whether 
 > external power 
 > supplies powering medical equipment (like blood-pressure 
 > monitors) are 
 > covered under the Medical Device Directive.  The power 
 > supplies are tested 
 > & approved to the appropriate medical standards -- only the 
 > format of the 
 > Declaration of Conformity is being discussed.  The MDD 93/42EC is at
 > <
 > http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG
:1993L0042:20071011:EN:PDF
>

My co-worker feels power supplies do not fall under the MDD due to Article 
1, section 2a.  Paraphrasing, it says the Directive covers devices that 
provide a medical function.  This would be the equipment powered by our 
product.
While I agree external power supplies don't provide a medical function, I 
think they fall under the MDD as an 'accessory', as described in section 
2b and section 1.

Opinions?  Links to interpretation papers?

Pat Lawler
EMC Engineer
SL Power Electronics Corp.

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