Brian, In this instance, the lab is correct. You’ve only partially quoted EHSR 1.7.1; in full it reads:
"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.” The key words are "which may be determined in accordance with the Treaty by the Member State in which the machinery is placed on the market”. France will say it all has to be in French. The Commission Guide to the Directive says: "The second sentence of section 1.7.1 applies when information is provided in the form of written words or text on the machinery, on a monitor screen or in the form of oral text provided, for example, by means of voice synthesiser. In such cases the information and warnings must be provided in the official language or languages of the Member States in which the machinery is placed on the market and/or put into service.“ You could have pictograms only, with the meaning explained in French (and other languages) in the manual, but you cannot have an explanation in English if it is not also provided in the local language. This may be a strict interpretation, and in practice, you may be able to ‘get away’ with a more relaxed approach, but the lab are correct in what they are saying. Bearing in mind that the French authorities may well take the same view, it would be wrong of them to take a more relaxed approach. Not the news you wanted, I’m afraid! Nick. On 9 Jun 2014, at 19:35, Kunde, Brian <[email protected]> wrote: > 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. 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