December 2019
Text by Ferry Vermeulen

Image: © Elnur Amikishiyev/123rf.com

Ferry Vermeulen is director at INSTRKTIV GmbH. He is a member of the tekom Europe advisory board for legislation and standards and speaks frequently at international conferences. His blog is read by over 15k people each month.


ferry[at]instrktiv.com
https://instrktiv.com


 

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IEC/IEEE 82079 and ISO 20607 on publishing information online

In 2019, two new standards saw the light of day: ISO 20607 and IEC/IEEE 82079. The trend of the paper manual becoming obsolete continues. A relief for many companies. But exactly how do we need to handle online instructions?

Many European Directives, such as the R&TTE, LVD and EMC Directive, were repealed or replaced in 2016, allowing companies to deliver the user instructions for many products only online. The new standards on instructions for use also offer new opportunities. For many products, it is no longer required to supply the full manual in the packaging. This digitization is a pretty logical step considering that 85 percent of European households had an internet connection in 2016, and Western Europe and Eastern Europe had a 75 percent and 60 percent smartphone penetration respectively.

In this article, I will discuss how you can legally digitize your product information, under which circumstances you can publish your documentation online, and in which cases print is still required. For this I will review the relevant parts of ISO 20607 and IEC 82079 that relate to online publication.

 

What does European legislation allow regarding online publication?

Before 2016, the obligation to deliver printed instructions with the product was usually not included in a European directive itself. It could be found in the documents accompanying the directives, for example in the guide that accompanied the old EMC directive 2004/108/EC. This EMC guide stated:

The Commission services have taken as a bench-mark that the information provided to the end-user has to allow him/her to use the apparatus without any further steps on their behalf. (…) It is not accepted (in other cases than those stemming from the view above) that electronic media or a hyperlink is sufficient as an alternative to information in paper copy. The end-user has an absolute right to quick and easy use of the apparatus they have purchased with no further obligations (such as access to the internet).

With the introduction of the "New Legislative Framework" (NLF), dealing with the marketing of products, and the subsequent replacement of several product directives in 2016, only a few guidelines remain that state that a paper manual is necessary. In fact, the Blue Guide (last update: July 27, 2016), which was developed for the implementation of this new product safety legislation, states the following:

Unless otherwise specified in specific legislation, whilst the safety information needs to be provided on paper, it is not required that all the set of instructions is also provided on paper but they can also be on electronic or other data storage format. However, a paper version should always be available free of charge for the consumers who request it.

This concludes that:

 

  • Instructions, unless specified otherwise, may also be delivered in a different format with the product, rather than in print.
  • Information about the safety/safe use of the product must still be delivered in paper form (hard copy) along with the product.
  • Any company must, at consumer request, make a hard copy of the user manual available to the consumer.

 

IEC/IEEE 82079-1:2019 and online publication

IEC/IEEE 82079-1:2019 Preparation of information for use is the successor to IEC 82079-1:2012 Preparation of instructions for use.

This international standard provides principles and general requirements for information for the use of products. According to the standard, information for use is necessary for the safe use of a product, helpful for the efficient and effective use of a product, and often necessary to fulfill market, legal, and regulatory obligations.

The standard has been developed by two convenors and 23 members from nine countries. Therefore, it has broad international consensus. Compared to its predecessor, it contains some major updates. 82079 is a so-called horizontal standard: It does not apply to just a specific product or sector, but contains rules across sectors for almost all branches of the industry. The standard defines requirements for the content, structure, quality, process, media, and format of information for use. Information for use is considered an integral part of the supported product.

Content for information for use is based on three pillars: instructional information, conceptual information, and reference information. Information for use may include various information products that are selected, presented, and delivered in different media to meet the needs of different target audiences. The concept of information for use according to the new standard is illustrated in Figure 1.

 

Figure 1: Information types can be used to create several information products.

 

The following items are new in 82079-1:2019:

 

  • Change of title. In the new title, "information for use" is used instead of "instructions for use" and IEEE has been added as the co-developer (together with IEC). "Information for use" was used to indicate content that covers more than instructions/activities or operations to be performed.
  • The standard’s requirements are divided into those for information for use and those for the information management process. It includes a separate clause with requirements for the information management process. This clause does not apply to consumer products.
  • The new standard describes clearly how to comply with both the requirements for information for use and the requirements for the information management process.
  • The new standard includes a new clause named "professional competencies", which states that the creation of information for use shall be assigned to competent persons and even gives clear requirements regarding proficiency level.
  • The principles of minimalism have been integrated into usability.
  • To enable a safe, efficient, and effective use of a supported product, 82079 divides information for use into three information types. These information types consist of conceptual information that the target audience needs to understand, instructional information to be followed or considered, and reference information to be consulted when needed.
  • The new clause on "structure of information for use" emphasizes the use of leading criteria for structuring.
  • A new clause on the "media and format of information for use" is included. It covers the former section "presentation of instructions for use" and more. This clause is relevant for the publication form of the information for use.

Standard 82079 has become less strict regarding the media and format of the information for use, stating that it should be "based on the needs of the target audiences". Easy and permanent access to information is considered important and that the chosen media are durable. As possible media that can be used, 82079 specifies a combination of text, photographs, safety signs, graphical symbols and illustrations, video, animated illustrations, speech, Braille, AR, VR, etc. According to 82079, the conditions of use need to be considered when choosing the media and format. For example, in the case of low light, the medium should light up the text. Speech should not be used in a noisy environment. Paper should not be used in wet environments or clean rooms. Depending on the needs of the target audience, information for use can be provided inside the packaging, on or within the product, on the packaging (but not limited to the packaging), on websites, or separately as collateral documentation.

Consider the following items when formatting and presenting your online information for use:

 

  • Make sure that downloadable information can be displayed on commonly used devices.
  • Make sure that text fonts, safety signs and graphical symbols are clearly legible and follow the recommended minimum sizes.
  • Maximize brightness contrast.

 

ISO 20607 and online publication of instruction handbooks for machinery

ISO 20607 for Instruction Handbooks was developed by ISO, the International Organization for Standardization (whereas the new 82079 was developed by IEC/IEEE). Standards 82079-1:2019 and 20607 are related: The current ISO 20607 standard is based on the 82079 standard and can be seen as an enhancement to 82079 that contains additional guidelines for developing instruction handbooks specifically for machinery. Therefore, any guidelines as described in 82079 have not been repeated in 20607, such as the principles of minimalism or requirements for the information management process.

The standard for machinery was developed due to the need to provide detailed safety specifications specifically for machinery. ISO 20607 also has a strong relation with the ISO 12100 standard for risk assessment and risk reduction.

As 20607 can be considered an addition to 82079, both standards should be applied when creating an instruction handbook for machinery. When you use both standards for the development of an instruction handbook, you create the highest possible presumption of conformity with the corresponding requirements for harmonization legislation.

Focusing on machinery and as an enhancement to 82079, 20607 covers the following topics:

 

  • Content and structure of the instruction handbook
  • Language and formulation/style guide
  • Forms of publication

20607 creates much more freedom regarding electronic distribution of instruction handbooks, compared to how this was interpreted in the Guide to Application of the Machinery Directive. The Machinery Directive does require that "Before placing machinery on the market and/or putting it into service, the manufacturer or his authorized representative shall provide, in particular, the necessary information, such as instructions." However, it is not mentioned in which format the instructions should be provided and if this must be printed and included with the product, or whether these can be provided online. The Guide to Application of the Machinery Directive states the following:

 

Section 1.7.4 does not specify the form of the instructions. It is generally agreed that all health and safety related instructions must be supplied in paper form, since it cannot be assumed that the user has access to the means of reading instructions supplied in electronic form or made available on an Internet site. However, it is often useful for the instructions to be made available in electronic form and on the Internet as well as in paper form, since this enables the user to download the electronic file if he so wishes and to recover the instructions if the paper copy has been lost. This practice also facilitates the updating of the instructions when this is necessary.

 

Although the Guide is not legally binding, it has always been generally agreed that at least the health- and safety-related information should be provided in paper form, if not the entire user instructions.

This might change as soon as 20607 is harmonized. Section 7 of the standard describes that the instruction handbook must be provided as agreed with the customer, taking into consideration the local legislation of the country where the machinery is placed on the market and/or put into service for the first time. Basically, it means that it is required to fulfill the (European and local) legal requirements and, if requirements are absent, the contract shall be taken into account. The contract can also be an addition to local legislation. For example, a manufacturer must have an agreement that regulates the provided languages and publication forms. In principle, the handbook can be a paper handbook, placed on an electronic storage medium (such as a CD or USB stick, or on a device accompanying the machinery), published online, or it can be provided in a visual or auditory form.

 

Conclusion

The paper manual is an eyesore to many marketers as well as information and UX designers. According to them, it does not align with the customer journey. That’s why the obsolescence of a paper manual is a relief for many companies, especially those within the consumer electronics market, who operate internationally and attach great value to cost reduction and customer experience.

The new standard provides more freedom regarding the publication. But how easy is it to provide instructions that are legally valid and only available online? When making your decision, you need to take into consideration agreements as well as local and European laws. In everyday life, determining what the possibilities are might still lead to confusion and discussion. Your decision will ultimately depend on:

 

  • What kind of product do I have (machinery, electrical equipment, toy, medical device)?
  • What legislation does apply and which standards do I want to apply?
  • Who is my target audience and what are their needs?
  • Where do I sell the product and what are the local regulations regarding the publication format?

Some say that there is still a lot to sort out and that there is no easy one-fits-all solution that can be applied to all member states. Others argue that the new standards offer more freedom. What do you think?