Machinery instructions: what they have to contain

The essential requirements for instructions are in section 1.7.4 of Annex I to the Machinery Directive 2006/42/EC. The section has three parts: general principles for drafting, the list of minimum contents and a rule for sales literature – it must not contradict the instructions on health and safety aspects.

Instructions are among the protective measures of the machine. They are the third and last step: what can be removed neither by design nor by safeguarding is communicated to the user. This also marks the limit of instructions – a notice does not replace a guard that would have been technically feasible.

The Directive sets out the minimum contents as a list. For structuring a manual it is more helpful to arrange them by the life phases of the machine. Not every item applies to every machine; whatever applies has to be included.

Every machine must be accompanied by instructions in the official language or languages of the Member State in which it is placed on the market or put into service. The language versions verified by the manufacturer bear the words “Original instructions”.

Where no such version exists for the country of use, a translation must be provided – by the manufacturer, the authorised representative or the person bringing the machine into that language area. It bears the words “Translation of the original instructions”, and the original instructions accompany it. The Directive makes one exception for maintenance instructions intended exclusively for specialised personnel mandated by the manufacturer: they may be written in only one Community language which those personnel understand.

The Directive requires information on the residual risks that remain despite inherently safe design and safeguarding. That presupposes someone has identified them. A warning in the manual is therefore never the beginning but the end of a chain: hazard identified, design solution examined, safeguarding examined, remainder documented.

For the manual this means that every warning names the nature of the hazard, the possible consequence and what the user has to do – and it stands where the action is described, not collected on page three. Twenty general safety notes at the front that would fit any machine do not meet the requirement better than five that belong to this machine.

The required content includes information on airborne noise emissions, and it is frequently forgotten because nobody has measured. To be stated is the A-weighted emission sound pressure level at workstations where it exceeds 70 dB(A) – where it does not, that fact must be stated. Where it exceeds 80 dB(A), the A-weighted sound power level of the machine is added. In addition, the peak C-weighted instantaneous sound pressure value must be given where it exceeds 63 Pa (130 dB).

The values are measured on the machine or established from measurements on technically comparable machinery; the operating conditions during measurement and the measuring method are stated as well. For hand-held and for mobile machinery the Directive additionally requires vibration data.

Two standards describe how to turn the requirements into a readable manual. EN ISO 20607 deals with the instruction handbook for machinery: structure, content and presentation of safety-related information. IEC/IEEE 82079-1 applies across products to information for use and sets out principles such as target group analysis, comprehensibility and consistent structure.

Both help to build a manual that is understood. The legal requirement, however, remains that of the Directive: a manual with a standard-compliant structure that omits the noise data is an incomplete manual.

The Machinery Regulation (EU) 2023/1230 applies from 20 January 2027. It expressly allows instructions to be provided in digital form. Conditions are attached: the machine, its packaging or an accompanying document must indicate how to access the instructions; it must be possible to download, save and print them; and they must remain available online for the expected lifetime of the machine, at least ten years.

If the purchaser asks for a paper copy at the time of purchase, it is provided free of charge. For machinery that may be used by non-professional users, the safety information essential for putting into service and using the machine safely must still be supplied on paper. Under the Directive in force today, by contrast, the European Commission’s guide to its application assumes paper as the general rule.