Re: European Community: Directive on Machinery

Subject: Re: European Community: Directive on Machinery
From: Rick Lippincott <rjl -at- BOSTECH -dot- COM>
Date: Wed, 26 Jul 1995 10:51:37 EDT

Alexander posted a rather lengthy document dealing with CE Mark requirements.

If this document is what I think it is, I may be able to cut through some
of the legalese and explain the impact it had on tech manuals at my last
job.

"CE Mark" requirements went into effect earlier this year. As we understood
it, to meet the CE Mark, we had to provide certain instructions in "local
language" when selling our equipment in Europe. There were two items required:

1) A safety manual
2) "Routine Operations" manual

The safety manual content is obvious: an overview of the equipment,
detailing -all- possible hazards, ways to avoid them, and preliminary
data on treatment if injured. (Poison control data, etc.)

The routine operations manual does not have to include -every- piece of
information in your doc set. It only need contain the typical information
encountered on a day-to-day basis. (I'm making this up as I go along, but
I'll use driving an auto as an example. You would have to include information
on starting the engine, shifting gears, braking and acceleration, turn
signals, lights & wipers, adding fuel, checking fluids. You would -not- have
to include changing a tire, changing oil, jump-starting a dead battery,
performing a tune-up,and the like.)

It was our understanding that the CE Mark requirements allow you to provide
"non-routine" instructions in -your- native language if you can make a case
that:

1) Translating highly technical terms will degrade the accuracy of the
information, or
2) There's a reasonable expectation that the "advanced user" will be
able to understand your language.

(Why even bother to issue an abbreviated document like that? Well,if your
doc set is fairly large, translation costs can start to add up after a while.)

At Eaton, we reorganized the doc set so that the routine ops were all
contained in one manual, safety info was in a second manual, and the
advanced operations were in three other manuals. The documents were prepared
in FrameMaker on UNIX, and we learned of a software package that will
translate Frame files while retaining full formatting. (The product is
from a company called Logos, in Mt. Arlington NJ. I don't have a phone
number for them any longer.)

Many of us have been dwelling about meeting ISO 9000 requirements, in order
to do business in Europe. Unfortunately, those are not the only rules that
will have an impact on us, if we expect to sell our products there.

Rick Lippincott
Boston Technology
Wakefield, MA
rjl -at- bostech -dot- com


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