This is a conundrum that regularly leads to different labels for different markets. An approach that uses pictograms and symbols only that might well be acceptable in the EU might well be judged to be legally insufficient for the USA market because it lacks warning text. Then once you put text on a warning label, it is natural for users to want to understand that text in order to protect themselves, and so will reflexively want it translated---and I can't blame them.
Mike Sherman Product Safety and Compliance Engineer Graco Inc. ----- Original Message ----- From: "Brian Kunde" <brian_ku...@lecotc.com> To: "EMC-PSTC" <EMC-PSTC@LISTSERV.IEEE.ORG> Sent: Tuesday, June 10, 2014 8:08:54 AM Subject: Re: [PSES] Machinery Directive 1.7.1 What I expect is that a warning label with pictograms and warning symbols which explains the warning good enough by themselves to not have to also be accompanied by translated text if I choose to include the English text on the label for another market. It is silly to think that if I get a marker and black out the English text on the label that only then would it be compliant to the all mighty Machinery Directive. I expect requirements to be not only clear and but also reasonable. Hey, I’m easy to get alone with. If I see a picture of a hand being ground up in some gears I don’t really care what language the text next is in. I wouldn’t be confused in the least. The Other Brian From: Anthony Thomson [mailto:ton...@europe.com] Sent: Tuesday, June 10, 2014 4:09 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Machinery Directive 1.7.1 Hi Brian, Your quotation of Directive 2006/42/EC 1.7.1 falls short of telling the whole story. 1.7.1. actually states "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. " So each member state is (quite rightly in my opinion) at liberty to dictate what language(s) they require safety warnings to be in for equipment destined for that country. Frankly, what else would you expect? Textual warnings applied directly to equipment must be unequivocally clear and understood by the person using that equipment. Even for French people :-) Just my two-penneth. Tony Sent: Monday, June 09, 2014 at 7:35 PM From: "Kunde, Brian" < brian_ku...@lecotc.com > To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive 1.7.1 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 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? It technically doesn't say it has to be on the product, 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. 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. ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to < emc-p...@ieee.org > All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas < emcp...@radiusnorth.net > Mike Cantwell < mcantw...@ieee.org > For policy questions, send mail to: Jim Bacher: < j.bac...@ieee.org > David Heald: < dhe...@gmail.com > - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to < emc-p...@ieee.org > All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas < emcp...@radiusnorth.net > Mike Cantwell < mcantw...@ieee.org > For policy questions, send mail to: Jim Bacher < j.bac...@ieee.org > David Heald < dhe...@gmail.com > LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to < emc-p...@ieee.org > All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas < emcp...@radiusnorth.net > Mike Cantwell < mcantw...@ieee.org > For policy questions, send mail to: Jim Bacher < j.bac...@ieee.org > David Heald < dhe...@gmail.com > - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
