Hello Richard:  What is the device?  read section 1 of IEC 950 (or any of its 
clones)...there are a number of electrical machines covered such as pencil 
sharpeners, paper joggers, etc.  Perhaps you could look at the scope of a few 
standards for guidance?  just my thoughts for what their worth...

Mel Pedersen                    Midcom, Inc.
Homologations Engineer          Phone:  (605) 882-8535
[email protected]       Fax:    (605) 886-6752

----------
From:   WOODS, RICHARD[SMTP:[email protected]]
Sent:   Friday, April 25, 1997 12:20 PM
To:     Safety; EMC
Subject:        ITE or Machine?

Consider a product that consists of a mains powered limited power
transformer with an SELV secondary connected via a 2 meter cable to a
table top mounted device that contains an electronically controlled dc
motor. There are moving parts from which the operator must be protected.
The device is activated by the operator when required, otherwise it sits
idle with no moving parts. The product as sold consists of the
transformer, cable and table mounted unit.

Since there are moving parts, this product is obviously a machine. It
must be determined if the product is subject to the Low Voltage
Directive. Failing that, it must be subject to the Machinery Directive.
One can argue that the product is mains powered and therefore subject to
the Low Voltage Directive. It can also be argued that the transformer is
subject to the Low Voltage Directive, but the table top unit with the
moving parts is powered by a voltage level that is outside the scope of
the Low Voltage Directive and is therefore subject to the Machinery
Directive. Which argument is correct?

Your thoughts would be appreciated.

Richard Woods
Sensormatic Electronics

Reply via email to