Thank you for the informative overview. I work for Excosoft; a software company that provides a CCMS for creating, managing, translating, and delivering end-user technical documentation for various products, including machinery. The new Machinery Regulation (MR) introduces new possibilities and requirements for providing end-user technical documentation and instructions for use (user assistance) for machine manufacturers. However, I find some aspects to be somewhat unclear. What are your thoughts on the following points: * A machine manufacturer can provide user assistance solely in digital form, but online delivery is not a must? It seems to be implicit that if user assistance is not available online, it means it has to be delivered in printed form. If the manufacturer provides online user assistance, it must also be supplied in printed form upon request. * You mentioned that simply providing PDFs is not sufficient. Does this mean the following scenario is unacceptable under the new MR? A manufacturer makes PDFs of manuals available on their website and puts a QR code on the machine interface that links to the PDF on the website. * Chapter II, Article 10 states, "Such instructions and information shall clearly describe the product model to which they correspond." How should this requirement be understood? For example, if a manufacturer sells variants of a machine (different pre-configurations) and creates one (1) PDF manual covering all variants, the user of a certain variant would need to identify the relevant pages for their specific machine variant and ignore the irrelevant ones. If a user mistakenly follows instructions valid for a different variant (thinking the page is valid for the variant the user is using) and this results in damage or injury, is the manufacturer in compliance with Chapter II, Article 10?
Thank you for a good overview of the new MR.
Thank you for the informative overview.
I work for Excosoft; a software company that provides a CCMS for creating, managing, translating, and delivering end-user technical documentation for various products, including machinery.
The new Machinery Regulation (MR) introduces new possibilities and requirements for providing end-user technical documentation and instructions for use (user assistance) for machine manufacturers. However, I find some aspects to be somewhat unclear.
What are your thoughts on the following points:
* A machine manufacturer can provide user assistance solely in digital form, but online delivery is not a must? It seems to be implicit that if user assistance is not available online, it means it has to be delivered in printed form. If the manufacturer provides online user assistance, it must also be supplied in printed form upon request.
* You mentioned that simply providing PDFs is not sufficient. Does this mean the following scenario is unacceptable under the new MR? A manufacturer makes PDFs of manuals available on their website and puts a QR code on the machine interface that links to the PDF on the website.
* Chapter II, Article 10 states, "Such instructions and information shall clearly describe the product model to which they correspond." How should this requirement be understood? For example, if a manufacturer sells variants of a machine (different pre-configurations) and creates one (1) PDF manual covering all variants, the user of a certain variant would need to identify the relevant pages for their specific machine variant and ignore the irrelevant ones. If a user mistakenly follows instructions valid for a different variant (thinking the page is valid for the variant the user is using) and this results in damage or injury, is the manufacturer in compliance with Chapter II, Article 10?