mrl news | Edition 2020.1 [EN]

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mrlnewsThings to consider when compiling instructions for useTips on structure and designThe Machinery Directive stipulates that machinemanufacturers must prioritise the elimination or reductionof potential risks in the design of their machines through‘inherently safe design’. Risks that cannot be eliminatedby design must be suppressed by additional technicalprecautions. The third measure is user information:manufacturers are obliged to warn users of the residualrisks by providing warning information and warningequipment on the machine itself and warning informationin the instructions for use.Legal classificationIn Germany, the 9th Ordinance to the Product SafetyAct (Machine Ordinance – 9th ProdSV) transposes therequirements of the Machinery Directive into domesticlegislation. Under the ordinance, a machine may onlybe sold if it satisfies the stipulations of the ordinance.Amongst other things, the ordinance stipulates that ‘inparticular, necessary information such as the instructionsfor use within the sense of Appendix I to Directive2006/42/EC shall be made available.’Content, structure and designAppendix I, Section 1.7.4 of the Machinery Directivesets out the general principles for the composition ofand minimum information that instructions for use mustcontain. Further content may be derived from productstandards and the risk assessment.The structure of instructions for use should be designedaccording to the life phases of a machine, and containthe following at a minimum:n Machine and manufacturer identificationn Safety information that relates to the different lifephases of the machine; intended use; misuse;reasonably foreseeable misuse; remaining residualrisks; target audiencen Technical data, general functional descriptionn Transport, storage, setup, assembly, installation andcommissioningn Operation, workflows and equipmentn Maintenance, service, disassembly and disposaln EC Declaration of ConformityThe Machinery Directive does not stipulate how theinformation should be structured or designed. Thus far,standard DIN EN 82079-1 ‘Preparation of instructionsfor use – Structuring, content and presentation – Part 1:General principles and detailed requirements’ was thesole reference. The standard outlines the basics for thecompilation and presentation of ‘instructions for use’ ofall kinds (including children’s toys), but specific writingrules and proposals for structure are only treatednormatively.The new standard DIN EN ISO 20607 ‘Safety ofmachinery – Instruction handbook – Generaldrafting principles’ is, however, tailoredspecifically to instructions for use for machines.This standard is classed as a ‘type B’ standard,and is harmonised with the Machinery Directive.Like DIN EN 82079, DIN EN ISO 20607 containsgeneral guidelines that must be followed in orderto comply with the Machinery Directive.Page 10Edition 2020.01
mrlnewsLanguageThe instructions for use must be included in the officiallanguage(s) of the community or Member State in whichthe machine is to be marketed and/or operated.It must also be available in the original language of thecountry of manufacture. These operating instructionsmust be labeled with “Original operating instructions”.Only maintenance instructions intended for use byspecialist personnel designated by the manufacturer maybe compiled in one language of the community that isunderstood by those specialist personnel.Paper format or electronic preparationThe Machinery Directive itself is silent on the form thatinstruction for use can take – paper or digital, and theGuide to Application of the Machinery Directive is oftenconsulted for advice. On this, Article 255 of that guidestates the following: ‘...It is generally agreed that allhealth and safety related instructions must be suppliedin paper form, since it cannot be assumed that the userhas access to the means of reading instructions suppliedin electronic form or made available on an Internet site...ConclusionThe Machinery Directive requires instructions for use tobe compiled as an integral part of the machine and hasclear stipulations on the content that must be included.Edition 2020.01Page 11
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mrl news | Edition 2020.1 [EN]

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