I used to avoid this by `(setq org-babel-use-quick-and-dirty-noweb-expansion 
t)'.

This illustrates the issue:

#+begin_src org

  ,* abc

  ,#+begin_src R :comment (message "running on empty")

  ,#+end_src

  ,#+begin_src R :noweb yes
  1
  ,#+end_src


#+end_src

The irrelevant, unnamed, empty src block its consulted via 
org-babel-get-src-block-info.  This runs the (message ...) expression.  Not 
much of a problem here, but I sometimes have a src block in my buffer that is a 
work-in-progress and has a header arg that calls a function I would not 
ordinarily have loaded.  When noweb does its thing, it chokes on the lack of a 
function.

Chuck

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