Not a silly question at all! Assuming none of the Machinery Directive exemptions apply, then it's a machine. The enclosure may make it a "safe" machine, but it doesn't make it a non-machine.
This is quite logical - it could be that the enclosure isn't strong enough, for example, and doing a machinery assessment would consider this. John C -----Original Message----- From: Mark Hone [mailto:mh...@wellmandefence.co.uk] Sent: 30 April 2012 14:12 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive silly question? Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: " an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application". So the silly question is, if the moving part is wholly contained within the equipment and is inaccessible, does the MD apply or do I apply the LVD? I have Googled this question and have found references that say the MD does apply (it's the enclosure that makes the moving part safe), and references that say the MD does not apply (as the moving part is wholly internal, one doesn't need to even consider it). I strongly suspect the former statement is the correct one. Your authoritative opinions are sought! With thanks in anticipation, Mark -- Mark Hone HESS Manager Wellman Defence Limited Dolphin House Williams Road Portsmouth Hampshire PO3 5FP T: +44 (0)23 9262 9239 F: +44 (0)23 9269 7864 E: mh...@wellmandefence.co.uk W: www.wellmandefence.co.uk ________________________________ Wellman Defence is a limited company registered in England and Wales. Company Registration No. 953609 Registered Offices: Wellman International Ltd., Newfield Road, Oldbury, West Midlands, B69 3ET, England. The contents and any attachments to this email include information that is private and confidential and should only be read by those persons to whom they are addressed. Wellman Defence Limited accepts no liability for any loss or damage suffered by any person arising from the use of this email. Neither Wellman Defence Limited nor the sender accepts any responsibility for viruses and it is your responsibility to check the email and attachments (if any). If you received this mail in error, please destroy and delete the message from your computer. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>