Annex 1 section 1.7.4 of the Machinery Directive contains as good a basic
desciption of what should be contained in an instruction manual as I know
of (although it's only in very general terms, of course). You can get the
full Annex free from

http://www.conformance.co.uk/CE_MARKING/ce_mech_anx1.html

As has already been stated by others, more specific guidance will be found
in product standards, although in my experience the requirements of product
standards are usually pretty general except maybe for a few very specific
requirements.

Balancing the genuine safety concerns with the 'no brainer' warnings is not
always easy. It's ultimately almost impossible to be objective about this
and it's one of the areas where some independent assistance from people not
overly familiar with your particular product might be helpful. (That could
be read as a plug for consultancy services, but it's not always necessary
to pay for good engineering advice - most engineers I know have friends and
acquantainces who would be happy to help out by reading through a draft
manual.)

I deal a lot with consumer goods, and I'd certainly recommend giving as
many 'no-brainer' warnings as possible with most domestic products. What
you're not allowed to do, however, is rely for safety on a warning to the
user against something which you know they are going to do anyway. CE mark
directives all require the manufacturer to consider 'foreseeable misuse'
and to take steps to prevent hazards becoming significant risks from such
misuse. For example, in the instructions for a hairdryer one can put a
warning that the user should not use the appliance with wet hands, but
you've also got to be pretty certain that the product is actually safe to
use with wet hands, since you know that's how a significant proportion of
your customers _will_ use it.

Taking the example of the 'unplug before servicing' warning, I'd think
carefully about leaving basic and common warnings such as this out of
instruction manuals even for products which are only ever going to be used
by experienced personnel. It's not difficult to see the logic which says
that since most equipment has a warning like this in the instructions, any
equipment which does not must be safe to service while still plugged in.
(It's not a line of logic I'd apply myself, but it's not difficult to
imagine a lawyer trying to apply it.)

The machinery directive specifically requires manufacturers to consider the
'acumen' of the users of equipment when preparing instructions and there's
an obvious difference between the requirements for (say) shop floor
operators and service technicians. However, consider for a moment that
someone trained as a mechanical technician probably won't know much about
electrical safety (and vice-versa) but in a busy factory environment, both
electrical and mechanical fitters may be called to work on any particular
fault. Each will need warnings that that other does not. It seems to me
that the primary difference which the acumen of the user will make is how
the information is presented, not which warnings should be in and which
should be left out.

Regards

Nick.


At 15:53 -0500 10/11/99, Russell, Ray wrote:
>Greetings,
>
>In this day and age of trying to cover your butt, from liability (especially
>in the USA), I have found it interesting that the  information in some User
>manuals are going to the extreme to warn the consumer, while other similar
>products have very few warnings.
>
>In addition, our European partner is balking at the warnings we now have.
>They state that since the instructions require that installation or service
>should only be a "qualified personnel" then this person should know some of
>the obvious dangers, such as unplugging the device before servicing.
>
>Now assuming that a product is approved to US and European standards, can
>someone recommend a guide that would help to define additional manual
>requirements for US and Europe?
>
>Thank you,
>
>Ray Russell
>Regulatory Compliance Engineer
>

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