Skip to content

The Third Level of the Hierarchy: Information for Use

2012 January 16
This entry is part 3 of 3 in the series Hierarchy of Controls

I’ve writ­ten about the Hierarchy of Controls in past posts, but I’ve focused on the ‘engi­neer­ing’ side of the con­trol equa­tion: Physical changes to machine design to elim­i­nate haz­ards, and mechan­i­cal or elec­tri­cal con­trol sys­tems that can reduce risk.

The first two lev­els of the Hierarchy, Elimination/​Substitution and Engineering Controls, are typ­i­cally more chal­leng­ing to apply in most people’s minds, because expert knowl­edge is required. These lev­els are also more effec­tive in con­trol­ling risk than the sub­se­quent levels.

The Third Level

iStock_000009386795Small - Photo of Instruction manualThe third level of the Hierarchy is ‘Information for Use’, some­times abbre­vi­ated as ‘IFU.’ This level is decep­tively sim­ple, and is fre­quently the level peo­ple want to jump to when the other con­trols seem too dif­fi­cult to imple­ment. Done well, infor­ma­tion for use can make a sig­nif­i­cant con­tri­bu­tion to risk con­trol. Unfortunately, it’s done poorly or not at all more often than it’s done well.

Information for use includes:

  • Instructions and Manuals;
  • Operator Device tags and Legend Plates;
  • HMI screens;
  • Hazard Warning signs and labels;
  • Training Materials (text, video, audio) and Training (face-​​to-​​face, webi­nars, self-​​directed);
  • Sales and mar­ket­ing materials.

Information for use is needed in all the stages of the prod­uct life cycle: Transportation, Installation, Commissioning, Use, Maintenance, Service, Decommissioning and Disposal [1]. At each stage in the life cycle, the con­tent of the infor­ma­tion and the pre­sen­ta­tion may be dif­fer­ent. In every stage it can make a sig­nif­i­cant con­tri­bu­tion to risk reduc­tion by com­mu­ni­cat­ing the safe approach to the tasks in that stage, and the risks related to those tasks. The infor­ma­tion should include the intended use and the fore­see­able mis­uses of the prod­uct. This is a legal require­ment in the EU [2], and is a best-​​practice in North America.

In this arti­cle I’m going to focus on instruc­tion man­u­als. If you’re inter­ested in Hazard Warnings, includ­ing signs, labels, and inte­gra­tion into man­u­als and instruc­tions, watch for a future post on this topic.

Legal require­ments and standards

In the European Union, the legal oblig­a­tion to pro­vide infor­ma­tion with a prod­uct is enshrined in law [2].
No North American juris­dic­tions make an explicit require­ment for instruc­tions or infor­ma­tion for use in law, but many prod­uct spe­cific stan­dards include require­ments for the con­tent of manuals.

CSA Z432 [3] out­lines require­ments for con­tent in Clause 17, and in EN 60204–1 [7]. IEC 62079 [4], pro­vides guid­ance on the design and pre­sen­ta­tion of instruc­tions. ANSI Z535.6 [5], pro­vides spe­cific instruc­tions on inclu­sion of haz­ard warn­ings in man­u­als and instructions.

Training require­ments are also dis­cussed in CSA Z432 [3], Clause 18.

5% Discount on ISO and IEC Standards with code: CC2011

In the USA, pro­vid­ing infor­ma­tion for use with a prod­uct is con­sid­ered to be sound ‘due dili­gence’, how­ever, pro­vid­ing infor­ma­tion on resid­ual risk is often seen by lia­bil­ity lawyers as dan­ger­ous, since man­u­fac­tur­ers are pro­vid­ing infor­ma­tion, in writ­ing, that their prod­uct is not ‘per­fectly safe.’ If you’ve read any­thing I’ve writ­ten on risk assess­ment, you’ll know that there is no such state as ‘per­fectly safe.’ If a haz­ard exists, a poten­tial for harm exists, a prob­a­bil­ity can be assessed and thus risk exists, how­ever remote that risk may be. I think that this argu­ment by some lia­bil­ity lawyers is fatu­ous at best.

Kenneth Ross, one of the lead­ing prod­uct lia­bil­ity lawyers in the USA, dis­cusses the require­ments for warn­ings and instruc­tions in an arti­cle pub­lished in 2007 [6]. In the arti­cle, he explains the US requirements:

Product sell­ers must pro­vide “rea­son­able warn­ings and instruc­tions” about their prod­ucts’ risks. The law dif­fer­en­ti­ates warn­ings and instruc­tions as follows:

Warnings alert users and con­sumers to the exis­tence and nature of prod­uct risks so that they can pre­vent harm either by appro­pri­ate con­duct dur­ing use or con­sump­tion or by choos­ing not to use or consume.”

Instructions “inform per­sons how to use and con­sume prod­ucts safely.”

A court has held that warn­ings, stand­ing alone, may have no prac­ti­cal rel­e­vance with­out instruc­tions and that instruc­tions with­out warn­ings may not be adequate.

Therefore, when the law talks about the “duty to warn,” it includes warn­ings on prod­ucts in the form of warn­ing labels; safety infor­ma­tion in instruc­tions; instruc­tions that affir­ma­tively describe how to use a prod­uct safely; and safety infor­ma­tion in other means of com­mu­ni­ca­tion such as videos, adver­tis­ing, cat­a­logs and websites.

The law says that a man­u­fac­turer has a duty to warn where: (1) the prod­uct is dan­ger­ous; (2) the dan­ger is or should be known by the man­u­fac­turer; (3) the dan­ger is present when the prod­uct is used in the usual and expected man­ner; and (4) the dan­ger is not obvi­ous or well known to the user.”

Read Mr. Ross’ lat­est arti­cle on warnings.

This prac­ti­cal and sen­si­ble approach is very sim­i­lar to that in the EU. Note the require­ment that “instruc­tions that affir­ma­tively describe how to use a prod­uct safely.” The  old list of “don’ts” doesn’t cut it — you must tell your user how to use the prod­uct in an affir­ma­tive way.

Second Best

So why is it that so many man­u­fac­tur­ers set­tle for man­u­als that are barely ‘sec­ond best’? In many com­pa­nies, the doc­u­men­ta­tion func­tion is:

  • Not seen to add value to the product;
  • not under­stood to have legal import in lim­it­ing prod­uct liability;
  • given lit­tle effort.

The per­cep­tion seems to be that man­u­als are pro­duced pri­mar­ily to fill fil­ing cab­i­nets and that cus­tomers don’t use the infor­ma­tion pro­vided. This leads to man­u­als that are writ­ten after-​​the-​​fact by engi­neers, or worse, the role of ‘tech­ni­cal writer’ is seen to be an entry level posi­tion often filled by interns or co-​​op students.

End-​​user train­ing is fre­quently given even less thought than the man­u­als. When designed together, the man­ual will sup­port the train­ing pro­gram, and the train­ers can use the man­ual as one of the pri­mary train­ing tools. This pro­vides con­ti­nu­ity, and ensures that the train­ing process is prop­erly documented.

iStock_000012657812Small - Techncial ManualMy expe­ri­ence is that few engi­neers are excel­lent writ­ers. There are some, no doubt. Writing man­u­als takes a sound under­stand­ing of edu­ca­tional the­ory, includ­ing an under­stand­ing of the audi­ence to whom the mate­r­ial is directed. The level of tech­ni­cal sophis­ti­ca­tion required for a sim­ple house­hold prod­uct is com­pletely dif­fer­ent from that required for the tech­ni­cal sup­port man­ual for an indus­trial weld­ing laser.
The engi­neers design­ing and inte­grat­ing an indus­trial sys­tem are often too close to the design of the prod­uct to be able to write effec­tively to the tar­get audi­ence. Assumptions about the level of edu­ca­tion that the user will have are often incor­rect, and key steps may be skipped because they are assumed to be ‘com­mon knowledge.’

Quality doc­u­men­ta­tion is also a cus­tomer ser­vice issue. Products that are well doc­u­mented require less cus­tomer ser­vice sup­port, and when cus­tomers do need sup­port, they are gen­er­ally more sat­is­fied with the result.

New Delivery Methods

The deliv­ery meth­ods for tech­ni­cal doc­u­ments have changed con­sid­er­ably in recent years. Large, ring-​​bound paper man­u­als are being dis­placed by on-​​line, inter­ac­tive doc­u­men­ta­tion that can be accessed at the user inter­face. The use of PDF-​​format man­u­als has jumped, and this brings in the abil­ity to link error mes­sages gen­er­ated by the con­trol sys­tem to the sec­tions of the man­ual that related to that aspect of the sys­tem. Video and ani­ma­tions can be added that pro­vide at-​​a-​​glance under­stand­ing of the oper­a­tion of the machin­ery. WiFi net­works in indus­trial facil­i­ties, along with the accep­tance of mobile pad-​​computing devices like the Apple iPad, mean users can have the instruc­tions where they need them, and tech­ni­cians and ser­vice per­son­nel can take the man­ual with them to the area where a prob­lem exists, and can use the doc­u­ments even in very low-​​light conditions.

Finding tech­ni­cal writ­ing resources can be a chal­lenge, par­tic­u­larly if you are look­ing to move away from paper to elec­tronic doc­u­men­ta­tion. The stan­dards men­tioned in this arti­cle are a good place to start.
Documentation can range from writ­ing through tech­ni­cal illus­tra­tions, ani­ma­tion and video pro­duc­tion. Finding indi­vid­u­als who can pro­vide you with pro­fes­sional ser­vices in these areas in a timely way and at a rea­son­able price is not an easy task. If you need assis­tance rang­ing from a few ques­tions that need answers to hir­ing a tech­ni­cal writer, Compliance InSight Consulting can help. Contact me for more information!

Are your prod­uct man­u­als as good as they could be? What kinds of chal­lenges have you had with get­ting them writ­ten, or used? Add your com­ments below!


5% Discount on ISO and IEC Standards with code: CC2011

[1]    “Safety of machin­ery — General prin­ci­ples for design — Risk assess­ment and risk reduc­tion”, ISO Standard 12100, 2010

[2]    “DIRECTIVE 2006/​42/​EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 May 2006 on machin­ery, and amend­ing Directive 95/​16/​EC”, Annex 1, Clause 1.7, European Commission, 2006.

[3]    “Safeguarding of Machinery”, CSA Standard Z432, Canadian Standards Association, 2004.

[4]    “Preparation of instruc­tions – Structuring, con­tent and pre­sen­ta­tion”, IEC Standard 62079, International Electrotechnical Commission, 2001.

[5]    “American National Standard For Product Safety Information in Product Manuals, Instructions, and Other Collateral Materials”, ANSI Standard Z535.6, American National Standards Institute, 2006.

[6]    K. Ross. “Danger! The Legal Duty to Warn and Instruct”, Risk Management Magazine, [web] 2007, Available: No longer available.

[7]      “Safety of machin­ery — Electrical equip­ment of machines — Part 1: General require­ments”, CENELEC Standard EN 60204–1, CENELEC, 2009.

Post By Doug Nix (94 Posts)

+DougNix is Managing Director and Principal Consultant at Compliance InSight Consulting, Inc. (http://​www​.com​pli​an​cein​sight​.ca) in Kitchener, Ontario, and is Lead Author and Managing Editor of the Machinery Safety 101 blog.

Doug’s work includes teach­ing machin­ery risk assess­ment tech­niques pri­vately and through Conestoga College Institute of Technology and Advanced Learning in Kitchener, Ontario, as well as pro­vid­ing tech­ni­cal ser­vices and train­ing pro­grams to clients related to risk assess­ment, indus­trial machin­ery safety, safety-​​related con­trol sys­tem inte­gra­tion and reli­a­bil­ity, laser safety and reg­u­la­tory conformity.

Website: → Compliance inSight Consulting Inc.


Series NavigationUnderstanding the Hierarchy of Controls
No comments yet

Comments are closed.

All original content on these pages is fingerprinted and certified by Digiprove
WordPress Login Protected by Clef
%d bloggers like this: