01/09/2023
Instructions for Use of Machinery
DEEPENING
According to the provisions of the Machinery Directive currently in force, each industrial machine must be accompanied by the instructions for use (RES. 1.7.4 of Annex I); in other words, although a different practice has spread among manufacturers, the instructions must be drawn up before the machine is placed on the market and, once it reaches the user/purchaser, the instructions must already be present.
With regard to the form, in relation to technological evolution, the question relating to the possibility to provide the manual in electronic rather than paper format is increasingly frequent. To date, however, reference must be made to the text of the Machinery Directive 2006/42/EC and to the Guide to its application adopted by the European Commission; paragraph 255 "Form of the instructions" establish that:
"Point 1.7.4 does not specify the form to be given to the instructions. It is generally accepted that all instructions relating to safety and health should be supplied in paper format as it cannot be assumed that the user has access to the means to read instructions supplied in electronic format or made available on a website. Internet. However, it is often useful to make instructions available electronically and on the internet, as well as in hard copy, as this allows the user to download the electronic format if applicable, and to retrieve the instructions if the hard copy is lost. This practice also makes it easy to update instructions when needed.”
It must be emphasized that at the time the Machinery Directive was adopted, the use of the internet was not yet so widespread among economic operators.
In the text not yet definitively approved of the New Machinery Regulation which will replace the current Machinery Directive 2006/42/EC, on the other hand, the obligation to supply the machine user manual in paper format has been removed; in fact point 1.7.4. establishes:
“The instructions may be provided in a digital format. However, upon purchaser’s request at the time of the purchase of the machinery product, the instructions shall be provided in paper format free of charge.”
The standard EN ISO 20607 explores the aspect relating to the drafting of machinery instruction manuals. The standard, aligned with ISO 12100, clearly establishes that the manual must be supplied in the form agreed with the customer, thus making it possible to supply the paper version or, alternatively, the digital one.
A worthy comment is that of art. 10 of the draft of the New Machinery Regulation according to which, subject to agreement with the customer, it is possible to deliver the Use and Maintenance Manual only in digital format with the following restrictions:
“Digital documentation: EHSRs 1.7.4 on instructions and Annex V on the manufacturer’s declaration of conformity allow that manufacturers provide digital instructions and the declaration of conformity. Nevertheless, a paper format is mandatory upon request.”
In summary: today it is advisable to comply with the provisions of the Machinery Directive, i.e. provide the use and maintenance instructions in paper format and wait for the entry into force of the Regulation to take advantage of the opportunity to provide the instructions only in electronic format.
According to the provisions of the Machinery Directive currently in force, each industrial machine must be accompanied by the instructions for use (RES. 1.7.4 of Annex I); in other words, although a different practice has spread among manufacturers, the instructions must be drawn up before the machine is placed on the market and, once it reaches the user/purchaser, the instructions must already be present.
With regard to the form, in relation to technological evolution, the question relating to the possibility to provide the manual in electronic rather than paper format is increasingly frequent. To date, however, reference must be made to the text of the Machinery Directive 2006/42/EC and to the Guide to its application adopted by the European Commission; paragraph 255 "Form of the instructions" establish that:
"Point 1.7.4 does not specify the form to be given to the instructions. It is generally accepted that all instructions relating to safety and health should be supplied in paper format as it cannot be assumed that the user has access to the means to read instructions supplied in electronic format or made available on a website. Internet. However, it is often useful to make instructions available electronically and on the internet, as well as in hard copy, as this allows the user to download the electronic format if applicable, and to retrieve the instructions if the hard copy is lost. This practice also makes it easy to update instructions when needed.”
It must be emphasized that at the time the Machinery Directive was adopted, the use of the internet was not yet so widespread among economic operators.
In the text not yet definitively approved of the New Machinery Regulation which will replace the current Machinery Directive 2006/42/EC, on the other hand, the obligation to supply the machine user manual in paper format has been removed; in fact point 1.7.4. establishes:
“The instructions may be provided in a digital format. However, upon purchaser’s request at the time of the purchase of the machinery product, the instructions shall be provided in paper format free of charge.”
The standard EN ISO 20607 explores the aspect relating to the drafting of machinery instruction manuals. The standard, aligned with ISO 12100, clearly establishes that the manual must be supplied in the form agreed with the customer, thus making it possible to supply the paper version or, alternatively, the digital one.
A worthy comment is that of art. 10 of the draft of the New Machinery Regulation according to which, subject to agreement with the customer, it is possible to deliver the Use and Maintenance Manual only in digital format with the following restrictions:
“Digital documentation: EHSRs 1.7.4 on instructions and Annex V on the manufacturer’s declaration of conformity allow that manufacturers provide digital instructions and the declaration of conformity. Nevertheless, a paper format is mandatory upon request.”
In summary: today it is advisable to comply with the provisions of the Machinery Directive, i.e. provide the use and maintenance instructions in paper format and wait for the entry into force of the Regulation to take advantage of the opportunity to provide the instructions only in electronic format.
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