Last edit: 26/04/2024
THE DOUBT
By working everyday together with manufacturers of machineries, we get frequentily asked the question “is it mandatory to give to our customer the Instruction Hanbook of the machine in papery format?”
CONSIDERATIONS
The publication on 18 April 2024 of the Guide to the Application of the Machinery Directive 2006/42/EC clarifies the fact that the manufacturer of a machine is not obliged to provide the respective instructions for safe use and declaration of conformity in paper form.
The obligation was due to the fact that, at the time of pubblication of the Machinery Directive 2006/42/EC, the use of the internet and other digital format wasn’t as diffuse and accessible as of today: so, to ensure that the user of a machine could access the respective Istruction of Use, the only viable option was to obblige the manufcturer to provide a printed version.
With the Machinery Regulation, published in 2024, this fact is recognized and so this obblige has been removed, not only because the type of communcation means that are available nowadays but to riduce the cost and the enviromental impact caused by giving the instruction hanbooks in papery format too.
Anyways, the new Regulation recognises that todays, in some environments, the access to digital format is limited so, to satisfy the needs of everyone, the Article 10 of the new Regulation will the report the following indication:
Article 10 – Paragraph 7 – Obligations of manufacturers of machinery and related product
[…] The instructions may be provided in a digital format. […] However, at the request of the user at the time of the purchase, the manufacturer shall provide the instructions for use in paper format free of charge within one month.
Today, in the EN ISO 12100:2010 standard is reported the following prescription:
Durability and availability of the documents: documents giving instructions for use should be produced in durable form (i.e. they should be able to survive frequent handling by the user). It can be useful to mark them “keep for future reference”. Where information for use is kept in electronic form (CD, DVD, tape, hard disk, etc.), information on safety-related issues that need immediate action shall always be backed up with a hard copy that is readily available.
From this prescription it seems like that today is possible to provide Instruction Hanbooks in papery format too but the standard precises that the informations regarding safety related aspects that need to be immediately available must be always supplied with an hard copy.
Either ways, in 2019 the standard EN ISO 20607 has been published. It deals with the drafting of the instructions hanbooks of machineries. It is alligned with the standard EN ISO 12100 but it clearly expresses that the instruction handbook must be provided in the form as agreed with the customer (papery and/or digital).
The new edition of the Machinery Directive Guide published in April 2023 states that as many as 93% of EU households today have access to the Internet. Under these circumstances, and in light of the new Machinery Regulation’s provisions on the format of the instructions, one can consider that respecting those provisions, including the obligation to provide the essential safety information in paper format in the case of non-professional use, also ensures compliance with the corresponding provisions of the Machinery Directive.
CONCLUSIONS
The Machinery Directive, the law of reference for assessing the conformity of machinery for industrial use, stipulates that the manual must be provided in a paper version. In 2023, the text of the Machinery Regulation was published, which only allows the manual to be provided in a digital version. Unfortunately, the Regulation will only come into force in 2027. However, the publication of the new Guide to the Machinery Directive in April 2024 already allows these documents to be supplied in digital format. Therefore, as of today, we consider it no longer necessary to provide instruction manuals in paper format unless expressly requested by the customer.