Creating user manuals that comply with the long list of requirements of the Machinery Directive is a challenging task.
Finally, a standard has been developed that specifically focuses on creating instruction handbooks for machinery. The standard helps anyone who is involved in the CE marking process of machinery.
In this podcast, I am interviewing Martin Rieder, who has been part of the committee that developed the standard.
Listen to the interview below and make sure to subscribe to the INSTRKTIV’S INSANE INSTRUCTIONS SHOW on your favourite podcasting platform. You can find the free transcript of this episode on my website as well.
SOME TOPICS WE COVERED:
- The relation with the 82079-1:2019 standard
- The relation with the ISO 12100 standard for risk assessment
- Using the standard to comply with the Machinery Directive
- Legal possibilities on publishing online
- Translating instruction handbooks
- Harmonization of the standard
- Practical steps on how to create compliant handbooks
LINKS MENTIONED IN THIS EPISODE:
Read the Full Podcast Transcript Below:
Ferry: Hi there, and welcome to this podcast. In this podcast, we're going to talk about the new standard for instruction handbooks for machinery, the ISO 20607 standard. Our guest for today is Martin Rieder who has been part of the committee that developed the standards. Martin is an entrepreneur, a safety expert, a speaker, vice-president of tekom Austria, lecturer and trainer. He is the CEO at CAVEO, an agency based in Vienna, Austria, specializing in safety management and documentation since 2014.
Martin and I know each other from the tekom Europe Advisory Board for Legislation and Standards, of which we are both an active member. Martin can tell us everything about the new ISO 20607 standard for instruction handbooks for machinery. Martin, welcome.
Martin: Thank you, Ferry. I'm delighted to be your guest today. I have nothing to add to your introduction, and I want to jump into the topic for today, the ISO 20607 standard.
Ferry: Yes, but before you do that, Martin, because as a preparation for this interview, I checked your LinkedIn profile and I saw that you mentioned that you have an industrial engineering background.
Martin: That's correct. I'm an industrial engineer. My focus in my daily work is on machinery safety, especially for steel plants, steel factories and big process industrial plants and industrial factories, as well as smaller equipment like lifting equipment, conveyors and so on and so on. My background is all the things about cost and the safe use of products and a good quality in engineering and the whole engineering process. Quality management is also part of my background.
Ferry: You were a CE product coordinator at the Austrian Chamber of Commerce.
Martin: That's correct. I'm a CE product coordinator. I did this course many years ago and now I'm a trainer in a course like this. Lots of people joined the program we offer to our clients or via different training companies.
Ferry: Do you mean with “trainer” that you are a lecturer or is that something different?
Martin: I'm the lecturer as well. Here in Austria, we call it a trainer if you're not in a university or a University of Applied Sciences, then you are a lecturer. Otherwise, you're a trainer for adults and people who are in business.
Ferry: Okay. Can you tell me since when you're involved in technical communication?
Martin: I'm working in the field of technical communications since 2008. I came to this field of work, there was no special reason why I started to work as a technical writer. I had no idea what technical writers do. I didn't know the branch and more than 10 years ago, I started a new job and the company was searching for an employee who is responsible for creating the technical documents. That was my first step into this branch.
A few months and years ago, I found out that this is my job I love to do. It's my passion and I made a small change of my focus in daily work to machinery safety in combination with technical writing so I'm a technical writer as well and I joined some course programs from tekom and other companies.
Ferry: Okay. You did quite some standardization work as you participated in a few committees, one of which is the 20607 standardization committee, which we're going to discuss in this episode. How did you get involved in this one?
Martin: After I got the information about this new project via email, I was not part of the working group of ISO because the 20607 standard is hosted by the International Organization for Standardization and its technical committee 199, and responsible for the development of the standards is the working group five. They already started the project in 2014 with the first discussions about the new standard, and in 2017, I joined the working group. At this moment or at this stage, the first draft of the standards was already created by the working group, so it was a little bit late but not too late to fix some problems.
Ferry: Right, and you're saying that this standard is being initiated by ISO. A few episodes ago, we discussed the 82079 standard for information for use, and this one was developed by the IEC and IEEE organizations. Where does this difference come from?
Martin: The difference is that the 82079-1 standard was originally hosted by then the European standardization body of electrotechniques. The basis is an electrotechnical standard and ISO itself didn't know anything about this standard. They didn't know that there is another standard for information for use existing anywhere.
Ferry: Right, but there is a strong correlation between the 82079 and the 20607 now, isn't there?
Martin: That's correct. That was one of the biggest problems we faced during the development of the final standard, because the participants of the working group five, they are mostly from the machinery safety and product safety and functional safety sector and with the same background. There was no technical writer part of this working group and after I joined the working group, I was the only technical writer in this working group and I was the first person who told colleagues that there is another standard existing and we have to look under the other standard because it's a horizontal standard and it covers not only machine, also other products, and it's a well-developed and well-settled standard in the world and in the branch of technical communication. That was a problem also, for me, as a new member of this working group. I was a rookie in there. We had to face this problem.
Ferry: When you were aware that there already was this 82079 standard or that this standard was being developed at that moment, why did you decide to develop a separate standard for machinery? Why do we need another standard for machinery only?
Martin: The thoughts of the former members of the working group five, the members who started this project in 2014 and 2015 were, on the one hand, they didn't know about this standard, the 82079-1. They didn't know that the standard is under development for the edition two which is already released in March. They thought that a standard in the field of the safety of machinery is necessary to concretize the safety-relevant parts of an instruction handbook.
Ferry: Meaning that this has to do with the risk analysis or risk assessments, possibly.
Martin: Yes. The 20607 standard is directly linked to the ISO 12100 standard. This is our main standard for risk assessment and risk reduction, and the third step of the risk reduction process is the instructions for use or the user manual or instruction handbook. The working group said that we have to concretize the requirements for user manuals for instruction handbooks according to ISO 12100 because it's not enough clarified in the 12100 standard, so the 20607 was born.
Ferry: Also, 82079 does mention that safety-related information is important, but it doesn't describe in much detail that the 12100 standard for risk analysis and risk-reducing measures needs to be applied or how it needs to be applied.
Martin: That's correct. In the end, now, we have the final standard of 20607 already released in the early June 2019 and the safety information or the safety-relevant information in this standard behind the 82079-1 standard. That's another problem for technical writers because you get a new standard from the field of machinery safety, but you did not get enough information on how to write a warning message, how to implement safety information in your instruction handbook.
That's the first point. You have to work with both standards so you get more information from 82709-1. Additionally, you have to work with 20607 as well.
Ferry: Actually, I think that's really good advice. You would say when a technical writer is going to develop user instructions or a user manual for machinery, he or she needs to apply both standards, the 82709 and 20607.
Martin: That's correct. That is my first giveaway for you to work with those standards. One background of 20607 is also that it is primarily made for non-experienced persons who work in companies of machine manufacturers with no experience in technical writing, with no training in technical writing, and the 20607 is like we call it a cookbook. You get a recipe for the content of an instruction handbook without any details, without any requirements for the writing process.
Ferry: Yes, because we discussed that during the 82709 episode as well and, Sven, who I was interviewing then, said that the 82709 is very general and does not contain very concrete requirements, like do this and do that, and he supposed that as a user of the standard, you want that, you want the standard to tell you to do this and do that but because it covers such a broad scope, you can't say that. It's always upon the knowledge and skills and then how the technical writer applies the standards. What I mean to say is, it's always up to the technical writer to ‘translate’, so to say, the requirements into a good manual for their product.
Martin: That's correct.
Ferry: This also applies to 20607.
Martin: You are right that you have to have some deep, well-trained competencies in technical writing or in between the field of technical communication to work with the 82709-1 standard. The standard gives you lots of information about the writing process, about the quality, about some principles like single sourcing, and so on and so on. The 20607 is as I said before, made as sort of a cookbook, it gives you some clear requirements and information, for example, about the content of an instruction handbook. The standard gives you an example of the content of an instruction handbook. If you were a non-experienced person working for a machine manufacturer and you haven't written instruction handbooks before, it's good to use the 20607 standards to get an idea about the content and about how to write the instructions inside the handbook, how to design it, how to structure it. It gives you more concretized requirements and information than the 82709-1 standard. The biggest standard is for professionals.
Ferry: Right, because the 82709 standard focuses on a really broad scope of products, and the machinery 20607 for instruction handbook for machinery focuses on machinery only, meaning that they give much more specific requirements for the contents of user manuals for machinery?
Martin: That's correct. The 82709-1 standard is a horizontal standard. It covers all types of products. Not only machines but also other products as well. That's why machine manufacturers have to work with both standards: because 82709-1 is like the big brother for technical writing and 20607 is the younger standard and focus only on machine safety and safety-relevant information inside an instruction handbook.
Ferry: You're saying that a technical writer or an entrepreneur or whoever is creating the documentation or the instructions needs to apply both standards, so both 82709 and 20607. However, I think neither of those has been harmonized within the European legislative framework. Is that correct?
Martin: That's correct at the moment, but the 20607 standard is on the way to become a harmonized standard to the machinery directive. It will happen maybe in the last month of 2019. It depends on how fast the commission is working and the date where this standard it becomes listed in the official journal of the European Union. On the other hand, the 82709-1 standard wants to become a harmonized standard as well, harmonized under the direction of general product safety.
In the end, in the best case, we will have two harmonized standards: 20607 is harmonized under the machinery directive and 82709-1 is harmonized under the general product safety directive. As a machine manufacturer, the machinery directive is your primary directive in cooperation with the general product safety directive.
Ferry: What does it mean when those standards are harmonized, whether it's under the machinery directive or the general product safety directive?
Martin: It means that if you follow the requirements of the standard, the harmonization says that you are fulfilling the requirements of the directive as well. You do not have to check the detailed requirements of the directive when you're following the standard. Therefore, it's very important to have a look at the Annex ZA. The Annex ZA gives you the information which parts of the directive are covered by the standard and if you follow the standard and you fulfill the requirements of the standard, you know which parts of the directive are fulfilled in one step.
Ferry: So the 20607 standard gives much more detailed requirements on, for example, the content of user instructions or on the way you present your user instructions than the machinery directive itself does?
Martin: That's correct. The 20607 standard concretize the requirements of chapter 220.127.116.11 except requirement (u), Requirement (u) is about noise emissions and vibrations. This is excluded in the scope of the 20607 standards because we have some other standards, which gives you more detailed information about how to warn against emissions of noise and vibrations, but 18.104.22.168 of the machinery directive is in more detail covered by the 20607 standard.
Ferry: Did you mention already when the standards will much likely be harmonized?
Martin: It's hard to say a fixed date because it depends on the working speed of the European Commission, but we accept it for the end of this year. Last week, we had another standardization meeting of the working group five which was held in Prague, in the Czech Republic. The information we got there is that it's in the best way. The head consultant was clause-positive so the European Commission can go on with this project, but first, the standard has to become EN: an European standard and after it becomes an EN standard there is a defined process, then it becomes a harmonized standard under the machinery directive.
Ferry: One of the controversial, maybe the most controversial topic was whether the standard is going to allow it to provide instructions in an electronic form or not.
Martin: Yes, this was a problem during the development of the standard because the requirements for the forms of publication were different from the 82709-1 standard. The 82709-1 standard, as I said before, is a well-developed standard, it's a modern standard, and it gives you the option to provide instructions or information for use in electronic form, in digital form, on different channels and ways. It depends on the product, on the intended use.
The 20607 was a little bit different with its requirements, but now in the final standard, it's harmonized between both standards. Both standards, 20607 as well as 82709-1 give you the possibility to provide the instruction handbook in an electronic form.
Ferry: 20607 gives a possibility dependent on what? On the intended use of your product as well or your machinery.
Martin: Yes. First, the most important thing you have to watch is the local legal regulations. If it's allowed in your country by local legal regulations to provide information for use in an electronic form, then you can do it, then you can follow the options of the 20607 standard.
Ferry: Are you aware of any countries that don't allow this?
Martin: As I know at the moment, for example, in Denmark the national authorities, the market surveillance authorities, are a little bit strict following the guide to the machinery directive. That's an endless discussion and what I hope will end, at the latest after the revision of the machinery directive, is the form of publication because the guide to the machinery directive says that the only safe way to provide instructions, especially the safety-relevant parts of an instruction handbook, is the paper form. The experts in technical writing know that the paper form is not only the safest way to provide safety-relevant information, it's also possible, it also depends on the product and the intended use of the product and the machine as well, to provide safety-relevant information in electronic form. I give you a short example. If you have a big industrial facility plant, there you have a central control room. If you need some information about a fault at the hydraulic engine or your conveyor belt makes some loud noise, you will not go to the basement to open a room and you will not search in thousands of pages of paper, "What happens when my conveyor belts make some loud noise?" You go to the PC in your control room, you open the PDF file, you're searching for, "Conveyor belt makes some noise", for example, and then you find the information much faster than in the paper printed documentation.
From my point of view, the electronic form is a useful help and the modern way. We know everyone, also in industrial facilities, they work with digital documents like PDFs and so on and so on.
Ferry: Yes, it totally depends on the application and maybe also your target audience, the user of documentation.
Martin: Definitely, that's very important to look during the information development process at what's your target group, what's the intended use of your machine and how is the environment where the machine is going to be used. Another example: for a hammer which is used on a construction site, it makes no sense to give a PDF file because when you have a problem with your hammer at the construction site, maybe it rains, you cannot look on your smartphone or you don't have a computer, then you need the paper.
Ferry: Like a paper manual in a clean room, doesn't really make sense for example?
Martin: That's correct. It depends. You have to decide what's the best way. That is a thing that should also be included in the risk assessment.
Ferry: That was my next question. I think it is not part of a risk assessment mostly, how the manual needs to be provided.
Martin: I absolutely made the experience that colleagues and machine manufacturers always or mostly miss discussing some risks and dangers coming from faulty or incomplete instructions for use. There is a big risk because if you do not get the relevant information on howto safely with the machine, it's a big problem.
Ferry: Yes, I understand. I don't do risk analysis myself according to 12100, but I know a bit of it. When you apply the 12100 standard for risk assessment, I think there is a structured way of doing this. For example, you have to identify the mechanical hazards, the electrical hazards, the radiation hazards, et cetera, the seven groups of hazards, but where are the user instructions included? How do you assess the user instructions during your risk analysis? Shouldn't the assessment of the user instructions be part of the 12100 standards or is it already?
Martin: No, it isn't a part of the list of risks in the 12100. That's one thing we want to get into the standard if the 12100 maybe becomes revised in the next years. It's also a project of the working group five which I'm a member of. I'm part of this project as well. Therefore, I hope that we have another group of hazards in connection to information for use and missing safety information. IT risks are also a big part which is missing in 12100. Therefore, it's very important to work with 12100 during the risk assessment and to have a look at the 20607 standard as well.
Ferry: All right, thank you. At the moment the committee discovered that there is a standard for information for the use, which is the 82709, while the 20607 was being developed already, did this affect the further development of the 20607?
Martin: Of course, completely and thankfully after several very, very hard discussions, the working group five made some critical insights to the 82709-1 standard. The only problem was the 82709-1 addition two was under development as well. It wasn't finalized so that some colleagues in the working group said, "No, it's not a relevant standard for us, because it's under development and there is an old standard. If we want to have a look into the standard, we look into the old standard."
That was a big problem because if you make some references to this standard, and you make the reference to the old standard and a few months later, the new standard will become published, you have a big conflict in working with the standard. We had long discussions about this, and now the working group five accepted that there is another standard and this other standard gives you more detailed information, and we have to look, and we have to align the standards together, especially the detailed requirements, as we discussed before the electronic form of an instruction handbook.
Ferry: All right. Another hot topic is always whether the instructions need to be translated or not. What does 20607 say about this?
Martin: Yes, that's a big discussion as well. The 20607 standard deals with this discussion in a very simple way. The 20607 says that you have to follow the local legal regulation, and if there are no requirements from the legal side, you have to define any translation of the instruction handbook in the contract. So then the contract is your legal document which has to be followed by the manufacturer, and then you have to translate the document in the form which both parties agreed. But in the European Union, we have the machinery directive and the machinery directive says that you have to translate the documentation into the national languages which are spoken there and which are used by your target group.
Ferry: Which makes sense I think, because with the use of machinery, a lot of risks are mostly involved, meaning that you want to warn your user, so the goal should be providing or selling safe machinery on the European market, meaning that when you don't translate your instructions, for example, I'm a Dutch manufacturer of machinery I send it to German clients when I provide a Dutch manual and they can't read it, I'm not selling safe machinery. How do you see this?
Martin: That's correct, that's very important. If we look outside the European Union, for example, the United States, they have also strict requirements in their standards that you have to provide the instruction handbook in English but not only in English, in American English and in some states of the United States, you have to provide a Spanish translation as well for example. It's the same thing we have in the European Union and this absolutely makes sense.
If you, as you said, a Dutch machine manufacturer and you deliver your machine to Germany, the German user cannot work with the original document, so they have to have a German translation. But very important is that you have to have your original document in your mother tongue, because otherwise, it can become a legal problem after an accident with your machine. Then you have to tell the authorities or the lawyer, "Okay, look in my documents, in the original documents. I gave the safety-relevant information, but in the translation, it's not correctly translated or it's not included in the translated document."
Therefore, you have to mark both documents with the original and translation of the original.
Ferry: Yes. As far as I know, that's a really strict requirement that comes from the machinery directive saying that you have to mention, I think it's most common to do it on the cover page of the manual, you have to say “these instructions are the original instructions”, or “these instructions are a translation of the original instructions”.
Martin: That's correct. One important thing is it's a big problem in working with the machinery directive that some machine manufacturers are providing only the translated document, but the machinery directive says that you have to provide the original document as well as the translated document, because if there is, for example, an accident which happens during the use of the machine in Germany, the German court and the German market surveillance authorities, they will look into the translated document and they will use an expert who speaks maybe the Dutch language, and then they look in both documents if the needed information is given and if all safety-relevant things are covered.
That's very important. Lots of machine manufacturers miss to do these and to follow the directive's requirement.
Ferry: For example, you are a manufacturer of machinery, you manufacture angle grinders or robot arms or whatever, and you're selling it to Belgium, for example, which officially has three languages like Switzerland as well, which is not part of the European Union. Let's say you're selling to Belgium and are there chances that local laws say that you have to translate your documentation to German, Dutch, and French, for example?
Martin: It depends on the product. If your product is an angle grinder, as you said before, then you have to provide the instructions for use in all four national accepted languages, but if your machine is an industrial plant which is installed on one place and it cannot be moved from one place to another, then you have to provide instructions for use only in the language which is spoken in this district or in this federal state, for example.
Ferry: The inclusion of it making it possible to provide electronic user instructions is quite a big breakthrough, I would say, in the field of technical communication. Are there any other big improvements?
Martin: Yes. First, the electronic form of publication is absolutely a big breakthrough and a big development also in standardization work. We have several standards, which have to be modernized in the next month and years giving you the requirements and the possibility to provide your user instructions in an electronic form as well. Therefore, tekom is heavily involved in lots of standardization projects, for example, me bringing in this development in other standards. Not only in 20607 and 82709-1, that are major standards, but also in smaller standards that cover requirements for the instructions for use.
Other developments which are covered by the 20607 standard is that you have to give IT safety-relevant information in your instruction handbook. This opens a new Pandora's box for machine manufacturers because if your machine, for example, is linked to the internet via electronic communication device, you have to give your user all the relevant information on how to prevent your machine from, for example, for hacking attacks, and you have to give all the relevant information which are necessary to keep them the machine in a safe condition.
For example, you have to give information about how to install a firewall, how to use the firewall, how to update your safety-relevant programs. For example, if you have magnetic walls, with an RFID chip to configure these walls at the site, you have to give the information under which safe conditions they both can be configured or tested. If information is missing, the instructions for use are faulty, and the whole product is faulty. If there is an accident maybe during a false configuration or someone made a hacking attack on your system and changes some parameters to make these walls unsafe, it's the fault of the machine manufacturer.
Ferry: This means that actually this kind of safety has been included in the traditional definition of safety?
Martin: Absolutely. In the future, it has to be a part of the risk assessment as well. Therefore, machine manufacturers, as well as technical writers, have to improve their knowledge about IT risks and IT safety.
Ferry: Right. Talking about the future, what do you think that major future improvements will be or at least developments when it comes to information for use for machinery or maybe in broader spectrum information for use in general?
Martin: I think a big development will be in the field of artificial intelligence, AI and KI, self-assembling machinery, self-configuring machinery. All the machines, if we just keep our discussion here in the field of machinery, is all the things, all the developments in the field of digitization of machines connecting to the internet, for example, the Internet of Things, then all the industrial plants which are built up under the focus of Industry 4.0 and therefore IT safety and all the relevant information for use, will be very important to be observed by the manufacturers as well as the technical writers.
Ferry: Okay, but for now we have to deal with the 20607 standard and then the enhancements in this standard. Let's say I'm a technical writer or entrepreneur or I'm selling machines and I want to apply the 20607 standard, or at least I want to create compliant user instructions, where do I begin?
Martin: If you're a machine manufacturer and you have to create the instruction handbook, the best way is to start with risk analysis. After that, you have to make some analysis about the product, about the tasks, which have to be done by the user, by the maintenance personnel, by the mounting or installing personnel. After that, you have to be aware of the target groups. I say target groups because it's mostly not only one target group, it's more than one target group which works with a machine, and then you have the structure to make a draft of the structure of your instruction handbook. After that, you have to fill the instruction handbook with all the content.
You start with the general content, all the general information, and then you complete the content with the safety-relevant parts. This should be in cooperation with the risk assessment. The risk assessment should give you all the information which has to be part of the instruction handbook, which has to be written by the technical writer or the person who writes the content. After that, you have to look under special needs, for example, IT security.
Ferry: Okay, that's more or less the process. You're mentioning that after you've written the main content, you will need to include the safety instructions. In this sequence, why first writing the content and then including the safety instructions?
Martin: That's my way to do a project of writing an instruction handbook. There are different ways to fill an instruction handbook with the content, but for me, it makes more sense to write the general information and the general content, and then I go through the risk assessment table, and then I check on which positions of my instruction handbook safety-relevant information are necessary.
Ferry: So you can determine whether, for example, a specific safety instruction is a general safety instruction or maybe it's just an installation safety instruction that needs to go to the installation chapter, or maybe it's a safety instruction that is really specific to one certain step, but then you will include it in that step only?
Martin: That's correct. It helps me to make a difference between the safety-relevant information, is it just a supplemental directive, or is it an embedded safety warning message? The reason why I fill in first the general content is exactly this, to fill in all the safety-relevant information in a structured way. It's my form of the writing process I wrote down for myself and for my employees, and it's a good way that works. It's a way which is also allowed by 82079-1 because 82079-1 deals with the information development process, and so I follow the requirements of the standard.
It's also a good chance for me to check if I filled in all safety-relevant information from the risk assessment to my instruction handbook. Otherwise, if you start to fill that instruction handbook, then you have to do the next step to check the instruction handbook with the risk assessment. It needs time. It's hard to find the structure and maybe, for my feeling, it's too late to do this.
Ferry: Yes, I think you mentioned some really good guidelines, some really good tips that will help any technical writers writing better documentation. Martin, thanks a lot. We're coming to the end of this episode. Sounds like you had some really serious discussions when developing this 20607 standard. One last question, was it fun as well?
Martin: Standardization is fun as well. Yes, it's very interesting to know the thoughts of the colleagues, their way of dealing with new topics, their way of dealing with older topics, and it's very good for me to be state-of-the-art and to know early enough about the development of standards.
Ferry: Thanks a lot, Martin for this interview. I think it's a lot of useful information. Thanks to all the listeners for listening and I hope you'll be back during the next episode. Bye-bye.
Founder of INSTRKTIV and keen to help users become experts in the use of a product, and thus to contribute to a positive user experience. Eager to help organisations to reduce their product liability. Just loves cooking, travel, and music--especially electronic. You can also find him on:
Profile Page, Linkedin, Instagram and Twitter!
You may also be interested in
02 April 2021
Do you need a user manual for face masks?
In this article I will explain the different face masks. I will tell you what the requirements for the instructions for use are. You will learn if a manual must be included or not. ...
08 January 2021
EU and US Regulatory Requirements for Electronic and Print-based Documentation
In this webinar, I will help you to determine what information should be included in the packaging and what content can legally be placed online to stay in compliance....