Hi Doug:


The definition you quote would mean that all CD and DVD
drives would be subject to the MD?  Fans in computers?


Best regards,
Rich



On 7/11/2014 12:00 PM, Douglas Nix wrote:
Carl, Paul, List members,

This is not gray at all. The assembly meets the fundamental definition of machinery from Article 2 of the Directive:

The following definitions shall apply:
(a) ‘machinery’ means:

— an assembly, fitted with or intended to be fitted with a
drive system other than directly applied human or
animal effort, consisting of linked parts or components,
at least one of which moves, and which are joined
together for a specific application,

— an assembly referred to in the first indent, missing only
the components to connect it on site or to sources of
energy and motion,

Based on this, I would see this assembly as falling into Article 13, “Partially Completed Machinery”. Compliance with Annex I is required, which will also cover the electrical safety requirements under Annex I, 1.5.1 Electricity Supply. This clause requires you to apply the electrical safety standards that you would use if you were applying the LVD.

If you want to discuss this more, feel free to contact me offline.

Doug Nix
d...@ieee.org <mailto:d...@ieee.org>
+1 (519) 729-5704

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