In message
<64D32EE8B9CBDD44963ACB076A5F6ABB0269B066@Mailbox-Tech.lecotech.local>,
dated Mon, 9 Jun 2014, "Kunde, Brian" <brian_ku...@lecotc.com> writes:
Here we go again. On and off over the last 30 years I have bumped heads
over having English Text on warning labels on Worldwide marketed
products shipped to non-English speaking countries. I was given the
impression that Europe was ok with English Text as long as it was
explained in the translated manual in an official language of the
country sold.
For this reason, we have been transitioning to use the new ANSI Style
Warning labels which includes a pictogram, warning symbol, and English
Text. But now I have been informed that a third party lab in France has
found our product to be non-compliant. Here is their reason:
"Warnings are not written in French on the machine and generate a
confusion for operators."
Is the third party lab correct and we need to remove all English text
from warnings
No, but under French law you probably do need to add the French words.
This is one of those typical French laws that is enforced on the fourth
Frewsday of every seventh month.
which include pictograms and symbols or are they misinterpreting the
requirements of 1.7.1, which says, "...warning must be expressed in an
official Community language..". What does "expressed" mean?
'given', 'printed', moulded-in' ,'raised on a casting', 'etched',
'stamped' ... you name it.
It technically doesn't say it has to be on the product,
I think it does: the heading of 1.7.1 says '.., on the machinery'.
only expressed. Can expressed mean explained in the manual?
This third party lab seemed to have misinterpreted several other
requirements on the Machinery Directive so we are hoping this is
another. I hate having to train third party labs in something they are
getting paid to know.
Any help, suggestions, or advice would be most appreciated.
Does you French agent know whether the test house is invoking the French
language law or just being picky? If they are invoking the law, you must
conform.
The Other Brian
PS: Here is the entire text of section 1.7.1 of the MD for your
reference.
1.7.1. Information and warnings on the machinery
Information and warnings on the machinery should preferably be provided
in the form of readily understandable symbols or pictograms. Any
written or verbal information and warnings must be expressed in an
official Community language or languages, which may be determined in
accordance with the Treaty by the Member State in which the machinery
is placed on the market and/or put into service and may be accompanied,
on request, by versions in any other official Community language or
languages understood by the operators.
________________________________
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
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