Last edit: 01/08/2023
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?"
Right now, the Guide of the Machinery Directive 2006/42/EC clarifies that the manufacturer of a machine must provide the Instructions Handbook and the declaration of conformity of a machine in papery format.
This is a thing beacause, 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 new version of the Directive (which should be published in 2024 under the aspect of Regulation) 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 E.S.H.R. 1.7.4 of the new Regulation will the report the following indication:
E.H.S.R. 1.7.4 – Instruction
[…] 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.
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).
Although the approach of the current Directive provides for the supply of the user manual and the declaration of conformity in paper format, it is clear that the new Regulation and the new Standards are moving towards supplying the manuals in digital format. Therefore, we do not consider it necessary to provide instructions in paper format unless expressly requested by the customer.