The Third Level of the Hierarchy: Information for Use

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, with lit­tle over­sight by qual­i­fied peo­ple.

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!

References

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.

Series Nav­i­ga­tionUnder­stand­ing the Hier­ar­chy of Con­trols

Author: Doug Nix

Doug Nix is Managing Director and Principal Consultant at Compliance InSight Consulting, Inc. (http://www.complianceinsight.ca) in Kitchener, Ontario, and is Lead Author and Senior 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. For more see Doug's LinkedIn profile.