One May Presume Conformity – EN ISO 20607 Now Listed as a Harmonized Standard under the Machinery Directive
Authors: Dieter Goetz, Martin Rieder
Original Language: German
Transcription: Dieter Goetz
For years now, various standardizing bodies have written about technical documentation and communication: for example, the VDI (Verein Deutscher Ingenieure/Association of German Engineers) with their standard VDI 4500 Sheet 1-4 (bilingual) or, on the international stage, ISO/IEC/IEEE with their standard IEC/IEEE 82079-1, Edition 2.
The IEC/IEEE 82079-1 standard is used as a basic tool by technical writers, as it standardizes things vital to technical communication: target groups, content, structure, processes, media and format or information models etc.
Now, a new standard from ISO is taking the stage. As previously reported, ISO 20607, intended for instruction handbooks for machinery, has been published in spring 2019. This is a standard reduced in scope to the safety-relevant parts of operation manuals. A wider scope is not required here, as technical writers rely on IEC 82079-1 and other established international standards for all other aspects.
Official Journal European Union (OIEU) – List of Standards Supporting the Presumption of Conformity as per Article 7
For about a year now, the European Union has published changes to the standards supporting the presumption of conformity to the relevant directive in this official journal. The latest update of the list for the Machinery Directive took place with decision 2020/480 of the European Commission on April 1, 2020.
We have discussed this several times in the past – it was the intention of workgroup 5 of ISO Technical Committee 199 to list ISO 20607 as a standard supporting the presumption of conformity and thus include it in the list. The latest decision did just that.
It was assumed that the entire standard would support the presumption of conformity. However, only certain parts of the standard assist in achieving conformity.
Applying ISO 20607 fully supports the requirements as listed under 126.96.36.199 of the Machinery Directive – except subitem u), on documentation of noise protection.
What Does EN ISO 20607 Involve?
This new type B standard was created to enable manufacturers of machinery to develop instruction handbooks conforming with the law and, thus, the standard reflects the demands of the Machinery Directive.
Instruction handbooks are an element of information for use/instruction for use. Information for use is standardized in more detail by IEC 82079-1:2019.
EN ISO 20607 regulates in clause 4, “Principles and General Information”but excludes sub clause 4.11 from the presumption of conformity. Sub clause 4.11 involves user information with regard to IT weaknesses. The standard instead points to the technical report ISO/TR 22100-4, Guidance to machinery manufacturers for consideration of related IT-security (cyber security) aspects, which was published as an addendum to ISO 12100 in December 2018. This technical report describes the field of IT security in greater detail.
Clause 4 of the EN ISO 20607 standard references Chapter 6.3, “Design and development, including review, editing and testing” of IEC 82079-1:2019 at this point.
In Clause 5, EN ISO 20607 regulates the “Content and Structure of an instruction handbook”. The standard simply provides a recipe for the typical content and structure of an instruction handbook. It also clarifies that this recipe is a mere recommendation, leaving it up to technical writers to decide what structure and content would fit their machine-specific operation manual. Needless to say, the well-known IEC/IEEE820179-1 provides deeper guidance at this point.
What Is the Purpose and Use of EN ISO 20607?
This standard allows a pragmatic assessment of the requirements of EN ISO 12100, clause 6.4, and is intended to be readable without enhanced knowledge of technical communication. This stands in contrast to the IEC 82079-1:2019 standard, which is more abstract and requires enhanced knowledge of technical documentation.
EN ISO 20607 provides the basic requirements for an instruction handbook for machinery – an important aspect for companies manufacturing machinery. This standard may be regarded as a first-aid kit to support companies without technical writers. These companies are thus given a guide enabling them to adjust their instruction handbooks to the requirements in the Machinery Directive.
However, the standard fails to answer profound questions the technical communication department staff may have. One example is warning messages; EN ISO 20607 provides only little information regarding their structure. A categorization we know from IEC 82079-1 or ANSI Z535.6 is missing entirely.
Overlaps with and contradictions to IEC 820791-1 have been resolved, thus eliminating conflicts between standards EN ISO 20607 and IEC 82079-1.
EN ISO 20607: Use for “quick and simple dishes”… plain instruction handbooks without having to delve into technical writing.
IEC 82079-1: Comprehensive scope delving deeply into the core of technical communication. It requires enhanced knowledge of technical editing and conceptual work.
On a day-to-day basis, we advise technical writers in the machinery sector to work from simple to complex, which means first fulfilling the requirements of EN ISO 20607 and then dealing with “all the advanced requirements and recommendations of IEC 82079-1.
Acquiring more competence in technical editing will likely reduce ISO 20607 to a “side dish” of standardization in any case, due to its limited scope of regulation.