Preparation of information for use (instructions for use) of products — Part 1: Principles and general requirements

Introduction

The IEC/IEEE 82079-1:2019 was jointly developed (as part of JWG 16 since 2015) and published by ISO, IEC and IEEE. The standard provides general principles and detailed requirements for the design and development of all types of instructions for information (aka instructions for use) that are necessary or helpful to users of products of all kinds, ranging from consumer goods to highly complex installations, industrial machinery, power plants or buildings. IEC/IEEE 82079-1:2019 cancels and replaces the first edition IEC 82079-1:2012 which, in turn, was based on and replaced IEC 62079 Preparation of instructions – Structuring, content and presentation. This 2019 edition constitutes a technical revision and it is published as a horizontal standard.

In the introduction to the standard information is classified by the following types:

• Conceptual information (concepts, safety notes, others),
• Instructional information (procedures, warning messages, others),
• Reference information (troubleshooting, maintenance schedule, others).

According to the scope of the standard, information for use is: necessary for the safe use of a product; helpful for the efficient and effective use of a product; and often fulfils market, legal, and regulatory obligations. Information for use of products applies to phases of the product life cycle such as transport, assembly, installation, commissioning, operation, monitoring, troubleshooting, maintenance, repair, decommissioning, and disposal, and the appropriate tasks performed by skilled and unskilled persons. IEC/IEEE 82079-1:2019 provides a generic framework for prospective additional parts of this standard and applies to information for use whether provided as electronic or printed information products. It is intended for use by all parties responsible for or involved in the conceptualization, creation, maintenance, translation, localization, integration of content, production, provision and evaluation, acquisition and supply of information for use. The aim of the standard is to provide these parties with the common and fundamental basis for developing information for use of supported products of the required quality. The document is intended to be applied and referenced in product-specific standards, including those that specify the content of information for use of those products, for example, IEC 60335 for all parts for household electrical products, ISO 20607 for machinery, and ISO/IEC 26514 for systems and software. It is intended as a basis to elaborate product specific requirements for target audiences or product information. As a horizontal standard is primarily intended for use by technical committees in the preparation of standards in accordance with the principles laid down in IEC Guide 108.

How does IEC/IEEE 82079-1:2019 differ from IEC 82079-1:2012?

According to the information supplied by ISO, IEC/IEEE 82079-1:2019 includes the following significant technical changes with respect to the previous edition:

1. The structure of this document has been rearranged in order to facilitate application of the standard and to make it easier to find information. Where possible, the language has been simplified.
2. Information for use is introduced as a generic term. Instructions for use is a synonym for information for use. Step-by-step instructions is used as a subset of information for use.
3. Clause 5 (Principles) is revised and focuses on the purpose of information for use, the quality of information and the process for management of information.
4. The process for preparation of information for use is integrated in the normative part and addressed comprehensively.
5. Empirical methods for the evaluation of information for use are described in the normative part.
6. The professional competencies needed for the preparation of information for use are addressed more comprehensively.
7. Some aspects have been added to general requirements for information for use for complex systems of systems.
8. Consideration is given to instructions for self-assembly products.
9. An informative annex providing guidance on the fulfilment of specified requirements is introduced.

In reality, the differences between IEC 82079-1:2012 and IEC/IEEE 82079-1:2019 are more fundamental and not necessarily positive– as discussed below.

What sort of information does IEC/IEEE 82079-1:2019 deal with, what has really changed and what requirements are being set?

Judging by the change in the standard’s name, the watered-down technical requirements and a more generic and horizontal approach to content and its specific use, one can only surmise that the aim was to develop a standard that would deal with intelligent information and digital content in general but this didn’t quite work out. The aim to move into the area of information/content rather than just instructions for use makes a lot of sense, except it should have been clearly stated in the scope and reflected in the contents of the standard properly. Unfortunately, this did not happen. Furthermore, the terminology and language that was used to draft this standard is awkward, inconsistent and does not support any of these aims because it lacks substance and reference to other relevant requirements, proper terminology and existing approaches to dealing with intelligent information, digital content and internationalization.

The standard generally classifies information as , conceptual information, instructional information and reference information. However, this is not developed into any logical model, there is no attempt at any information mapping scheme that would show potential interactions and the information product development and the output examples do not seem to follow from any comprehensive model approach or provide any practical references for information developers.

When talking about global digitalization and intelligent information, what typically comes to mind are the following:

• content structured for storage, retrieval and reuse.
• strategies used for developing and managing content as a corporate asset;
• efficient us of processes, people, and technologies;
• scalable content management approaches;
• optimized authoring and content management processes;
• automated processes that support the reuse of various content components
• personalized content that serves different purposes, can be marketed and delivered via multiple platforms/channels to different target audiences
• metadata and indexing algorithms
• analysis of how digitization and the various social media influence information processing and dissemination, etc.

IEC 82079-1 addresses strategy and information management process (clause 5.4 and 6), professional competences (of the people involved) (clause 10), media and format (clause 9), structure and information delivery (clause 8). In that sense, it covers some of the points I’ve listed above but, once again, this is done in a very general and convoluted way.

The following four process groups for the planning, design, production, and sustainment of information for use are distinguished:

1. Analysis and planning of information
2. Design and development (including review, editing, and testing)
3. Production and distribution
4. Sustainment (including maintenance and improvement)

The standard contains recommendations for hierarchical structuring information so that only relevant information is delivered to the target audience (clause 8) but specific requirements or references to specific frameworks are not provided.

When it comes to the digitization of information, IEC/IEEE 82079-1:2019 is much less specific than its predecessor. Media and format requirements (clause 9) are also much less restrictive than before. It makes sense to align some of this with the needs of the target audience (e.g. printed text is not always required, not everybody wants or needs a big manual etc.) but there are no specific guidelines provided and it mostly boils down to general remarks that it is important that the media allow easy and permanent access to information for use and the media should be appropriate.

Clause 10 deals with human resources. According to the standard, the creation of information for use shall be assigned to competent persons but the only indication of actual requirements is included in the definition of the term itself (3.3). There is a lot of general talk about competence requirements in IEC 82079-1 but unfortunately no specific qualification requirements are provided anywhere and recommended levels of proficiency are impractical, non-standard and without reference to any recognized framework (Level 1, Level 2, Level 3), outdated (e.g. obscure reference to “skilled person” (3.36)), and hence quite arbitrary.

For example, ISO 17100:2015 Translation services - requirements is referenced in the context of the translation process (in a note) instead of being referenced directly in the clause of the standard dealing with required translator competence requirements. Not only is the standard terminology related to translation and its stages completely incorrect here but the translator competences in IEC 82079-1 are much lower than the minimum competence requirements of ISO 17100 and minimum translator qualifications or the qualification requirements of other people involved in the process are not mentioned at all. Furthermore, the key requirement of ISO 17100 which deals with compulsory revision (“the four eye principle”) which was included in IEC 82079-1:2012 previously is now gone. It is hard to understand what was the reasoning here. Why not reference the requirements set out in a recognized translation industry-specific standard in the context of the translation process and translator competencies? If IEC/IEEE 82079:2019 aims to establish standards for the whole information (instructions for use) development process and this document does not reference, in the appropriate context, recognized industry standards that set the minimum human and process requirements for key parts of the process (i.e. ISO 17100 - translation, revision, review) then someone must have missed the whole point of standardizing specific processes and services in order to achieve the required result. What is more, the IEC/IEEE 82079:2019 now does not contain any minimum requirements in this area, so the competence and process recommendations of the people involved are now completely meaningless and one cannot talk about any compliance reference scheme here. From that perspective, it is impossible to see how IEC/IEEE 82079:2019 aims to raise the bar and promote standards for processes. How can one realistically attempt standardization of, for example, “competent person” (3.3), “information quality” (3.20), “professional competencies” (clause 10), “safety-related information” (7.11), “information quality” (clause 5.3), “risk management” (clause 6.2.7) or “quality assurance” (clause 6.2.12) or “competencies of translators” (10.4) without setting any real (measurable) requirements as to qualifications and documented competence of the people involved in the process of producing and translating information or without setting a strict requirement that all translated content shall be at least revised once by another competent person prior to its approval for use?

Conclusions

It is a pity that IEC/IEEE 82079:2019 lowered some of the requirements contained in the previous version and did not correctly reference other standards that deal with various aspects of the information/content development process (the obvious and lamentable lack of proper reference to ISO 17100 aptly illustrates this point). The standard is quite lengthy now (130 pages) and there are a lot of recommendations and general statements but there are very few actual requirements for anything included in the standard.

It seems that IEC/IEEE 82079:2019 was intended as a generalist standard for dealing with intelligent information and tries to address some of the digital content issues and in theory it was supposed to be a requirements standard but either intentionally or unintentionally it is actually a guidance standard because it has failed to set any strict requirements in the key areas and process stages. Some of the key concepts of information management best practice certainly underly the IEC 82079;2019 standard but it is difficult to pinpoint specific requirements or guidelines that would directly address the challenges of global digital economy (and society) in need of intelligent information management. From my experience, this will in practice make this standard non-certifiable for, in spite of the efforts to provide guidance on evaluation (Annex A), it is very difficult to audit fulfilment of requirements that are either not stated explicitly or not objectively measurable. In such cases, the certification schemes are usually convoluted, non-transparent, non-objective, complicated and costly (which invariably has a negative impact on standard adoption and general usage).

Some of the other problems that this standard has not managed to overcome also boil down to linguistic issues. It is obvious that the standard was developed from different sets of documents and mainly by non-native English speakers and hence it does not reference many key terms and concepts used by digital content developers and used within the sector. The standard does not completely ignore typical terminology and issues but many of these concepts are well hidden in incomprehensible clauses and some of the key terms are simply not used. Apart from the absence of requirements and failure to reference relevant industry standards, my main objection to IEC/IEEE 82079:2019 is the lack of relevant requirements and not enough attention to editing and adherence to linguistic conventions (including failure to comprehensively use specialist/standardized terminology). It is clear that professional editing and more input from native speaker experts would certainly have improved this standard a lot and made it not only more readable but also more translatable into other languages (which is still a requirement in most countries). It is a great pity that the editors of this standard did not implement their own authoring best practice or refer to existing editorial and simple language standards as well as ISO terminology resources when drafting this extensive and convoluted piece of “information for use”.

General information:

References:

https://www.iso.org/standard/71620.html
https://standards.ieee.org/standard/82079-1-2019.html

ISO 17100:2015 defines a set of best practises for managing translation services. Adhering to these best practises helps design a smoothly run translation process that delivers a quality translation.

ISO published this standard on 1 May 2015 as the first international standard for translation service requirements. While it is not the only set of best practise for translation out there it is definitely the most important one. This blog post will give you a short introduction to ISO 17100, explain some of the main requirement and show why it is important.

ISO 17100 was based on the previous European standard EN 15038:2006. This standard was developed within CEN and was published in May 2006. Since ISO now has a very robust subcommittee (TC37/SC5) that deals with all translation, interpreting and related technology issues it was deemed the best host for a new international translation standard.

In spite of the fact that ISO 17100 was based on EN 15038 it is a completely reworked and updated standard and it went through the complete standardization process at ISO. The result is, I believe, a very good standard which servers well translation service providers (TSPs), buyers of translation and the community.

There are several requirements which the TSP must adhere to in order to meet the requirements of ISO 17100. The TSP needs to acquire qualified and competent human resources and proper technical resources, and design process workflows which meets the requirements of the standard. The standard also states that the TSP is fully responsible for the entire translation project.

Human resources are very important to the standard. There must be a documented HR process in place. The standard sets out specific qualifications and competences for the various people involved in a translation project such as translators, revisers and project managers. However, it is not enough for the translation company to check that people have these competences but they must also be keep on record and updated regularly.

ISO 17100 states that there must be a written agreement between the client and the translation service provider. If the client and the translation company come to this agreement over the phone or email, the translation company is expected to write up the agreement and send it to the client as confirmation of what has been agreed. The standard also makes sure that the client knows beforehand what the translation project will cost because they receive a quote from the TSP.

Communication is essential to this standard. ISO 17100 states that queries in both directions must be dealt with effectively and the same applies to feedback which has to be relayed to all the individual involved in the project. It also specifies that there must be a process for communicating any information relating to linguistic specifications.

In all cases the workflow for an ISO 17100 translation project shall involve translation as well as full revision of the target text. Both the translator and the reviser shall have the same high qualifications and competences. This ensures that the principle of two pair of eyes is applied in the translation process and this is very important in ensuring quality. The project must also be managed by competent project manager who can demonstrate their qualifications.

These requirements jointly ensure that a translation performed according to ISO 17100 should be a quality translation. The standard also ensures that buyers of translation can be reasonably confident that they are working with a professional translation company who is using industry best practises to provide high quality translation service. More information on implementing ISO 17100 is available here.

Following a period of relative calm, a new series of tweets, a blog article by Arle Lommel on 27 April, and a rather strange email from a French LSP recently appeared on the grapevine stating, in general, that: 1) it has been announced that the European Telecommunications Standards Initiative (ETSI) have been selected by LISA to take over their ‘open’ industry standards, 2) that the European Telecommunications Standards Initiative (ETSI) “has agreed to accept responsibility for the LISA open standards works”, and 3) that this is very good news.

Firstly, I have not been able to find any such “official announcement” by ETSI or LISA to this effect – on their website or anywhere else, so I am very much confused about who exactly has made this announcement on behalf of the entities in question and on what authority. Secondly, the only people that seem to be saying that this would actually be good news and welcomed by the industry are people that are not actually involved in standards work, and Arle Lommel.

Well, if these unconfirmed announcements turn out to be true, I don’t think it will be particularly welcomed by those in our industry who are actually involved in, or knowledgeable about standards, and I personally would not call any such development “good news”. On the contrary, it would mean that once again the ambitions of some individuals and strange goings-on have taken precedence over openness, best practice and looking out for our industry’s best interest.

I have already mentioned what was stated and implied in the above mentioned communication and I think several matters require clarification in this context. The facts concerning the potential overlap in the scope of the two organisations are as follows:

1) ETSI is a respected standards body and has developed some important standards in some technical fields. Their work to date has fitted exactly their own description of themselves as producing: “globally-applicable standards for Information and Communications Technologies (ICT), including fixed, mobile, radio, converged, broadcast and internet technologies” (source: ETSI website).

2) The LISA standards are XML standards for the translation and localisation industry, and that is a completely different field of specialisation. It is true to say that the ‘communicative” element is inherent in many technologies, standards and activities but to say that there is any real overlap or synergies between what ETSI has been involved in so far and the LISA standards efforts, would be untrue. The fact is that ETSI deal with the underlying technologies used to transfer data in different systems while the LISA standards were concerned with language assets. Therefore, it seemed ridiculous to me from the beginning that anyone would seriously suggest ETSI as a continuator of the LISA work on our industry standards.

I have been involved in standards development in the translation industry since 1998 and have worked with both OASIS and ISO TC 37 TCs. As long as I have been involved with our industry standards I have never heard any mention of ETSI as an organisation which was interested in developing standards for the translation and localisation industry. It was recently mentioned in a blog by Arle that public opinion within our community was divided on this subject ‘with larger users tending to support ETSI and tech developers tending more to support OASIS.’ Frankly speaking, I find this statement incredible and unbelievable, and I am prepared to bet that by “larger users” he actually means a couple of companies, and he should definitely say who they are. In fact, I would love to see some solid data and names to support this improbable statement about our industry’s support for an organisation that most people have never even heard of.

Another fact, I have been told, was that ETSI has in fact been lobbying some large companies to get their support for moving into ‘a new field of standards development – namely the language industry’. But there is surely a huge difference between planning to move into a new field and begin work on some new standards, and actually claiming any experience or expertise in this field and making a serious bid to take on the work carried on for over two decades by many industry experts. Another fact that I find strange in these lobbying efforts is the idea that ETSI and the supporting companies would initiate an unfair campaign together against other standards organisations such as OASIS and Unicode, who are firmly established in our industry for standards and would be considered as logical heirs to the LISA body of open standards both by industry experts and laymen alike.

I fully appreciate that ETSI might like to broaden its ICT standards base to include language industry standards, and they may see acquiring the LISA standards as a way of doing this. I can also fully appreciate the fact that they might be lobbying for the LISA standards by asking Arle Lommel to make all sorts of more or less substantiated statements, or involve  a friendly French LSP (from their home turf) to do some enthusiastic PR on their behalf, or even the fact that they might think that a couple of phone calls to some managers might be helpful to their cause. In other words, it is perfectly valid for ETSI to want to broaden their scope, but I do not see how this benefits the translation and localisation industry, and I do not understand why the new ETSI pundits and lobbyists take it upon themselves to also mislead and misinform the general public about certain fundamental facts.

One such misleading fact is that ETSI allows any expert to be involved in standards development whether or not they are members of ETSI and there are no fees involved (as is the case with OASIS or Unicode). It’s an interesting piece of news, except it seems to be far from accurate. In fact, at ETSI, just like any other standards organisation, technical committees (TCs) are actually responsible for standards development and they are open only to full and associate members. Section 1.4 of the ETSI Technical Working Procedures states clearly who can participate in technical committees. It also states that observers and non-members are only allowed to attend meetings on an exceptional and temporary basis and must apply to attend in writing. The authorisation to attend is limited to three meeting or six months whichever is shorter. By default of course, such observers have no vote or any real say in the actual standards development, their participation is subject to approval and might be difficult to achieve in practice or turn out to be a futile exercise. Another misleading suggestion was that non-members would be welcome in the ETSI Industry Specification Group which a number of people have said that ETSI will establish for the translation and localisation industry. However section 3.4 of the ETSI Technical Working Procedures sets the same stipulations as above and allows only for participation of non-members on an exceptional and temporary basis. There is no mention of a time limit here, but there is mention that non-members will have to pay a per meeting fee and will have no right of vote. So, it seems, that the ETSI rules are quite typical, and there are no special conditions or preferences, so nobody should be making any promises or suggestions otherwise. Similar to all other organisations, at ETSI you don’t get to have much say unless you join properly and pay a membership fee. Also, you can ask or be asked to participate as a non-voting expert for free (or at a lower fee) but your request will be processed according to similar procedures as anywhere else and your power to influence the proceedings might be very limited. One way or another, you will have no real say for free, and the saying that ‘there is no such thing as a free lunch’ still applies.

So, to sum it all up: 1) we are being told by certain individuals that ETSI has made an official statement to the effect that they will formally be given (or transferred) the LISA standards and will be in charge of maintaining and developing them from now on. But, such an official announcement does not seem to have been formally issued so far by LISA or ETSI, and no details of any such deal have been disclosed; 2) We are being told that this is ‘great news’ because ETSI is the best possible ‘location to host the LISA standards’. But there is absolutely nothing to substantiate this claim because ETSI has neither the record,  nor expertise in translation and localisation standards work, and seems a very unlikely candidate for any such responsibility by comparison with, for example, OASIS or Unicode.  – what is more, ETSI’s focus is primarily on Europe and this important point seems to have escaped the attention of many people; 3) We are being told that ETSI allows non-members to participate in their technical committees and Industry Specification Groups without any charges. The suggestion is that being involved in standards development within ETSI will be for free (as opposed to the cost involved when working with organisations like OASIS, Unicode or W3C). According to a very reliable source – published ETSI directives - this is not the case. In fact, if you look at the membership fee pricing scheme at ETSI, it appears to be a very expensive organisation to join, if you actually wish to become involved in standards development.

Therefore, given the above facts, we must conclude that the pundits lobbying on behalf of ETSI must either be completely ignorant of the actual facts and rules that govern standards development and industry experts groups participation at ETSI, or they are spreading silly gossip and misleading us on purpose. I cannot help but wonder what might be the goal behind this misinformation campaign and what is the real agenda. It will be very interesting to see, for example, if and who ETSI decides to employ as industry consultants and what they refer to as “Specialist Task Force Experts”.

The OSCAR group which developed the standards within LISA have officially proposed that the standards should be put in the public domain so that any organisation could work with them. The LISA members that I have personally spoken to in the past month and various standards development experts who have voiced their views at events, or in various online discussions, are predominantly in favour of the LISA standards being taken over by a dedicated industry standards organisations such as OASIS. Recent developments, would seem to suggest, that in spite of the prevailing opinions, campaigning on behalf of ETSI is going strong. Either, this is all codswallop or somebody at LISA has suddenly decided that the standards had to be transferred to one specific organisation, and that organisation is ETSI. It is a pity that the real justification for this is not being provided, and people are being misled once again. I have seen nothing to convince me that ETSI is a good home for the LISA standards, and I am not impressed by some of the lobbying activities going on. It is my opinion that there are not enough people doing the actual work of developing standards for translation and localisation to justify all this sort of political campaigning. At the end of the day, I still hope that facts and reason will prevail, and all will be well in the world again.

At the end of February 2011, LISA, the Localization Industry Standards Association, announced it was insolvent and was closing the organisation. LISA has been around since 1990 and it is interesting to note that all of the translation companies who were involved in founding LISA (Berlitz, Mendez, Softrans, Stream International and Bull International Localization Organization) no longer exist as separate companies.

For me, and I think many others, the most important part of LISA’s work was on standards development. They managed to attract a number of people at any early stage who made an important contribution to the development of technology standards for our industry. The three most important LISA standards are TBX, TMX and SRX. The other standards which LISA’s OSCAR group worked on are:

• Global information management Metrics eXchange (GMX) - Standard word and character counts for consistent costing and estimating.
• XML text memory (xml:tm) - For storing text and translation memory in XML documents.
• Term Link - The lightweight standard for linking XML documents to terminology resources.

All the LISA standards are important but GMX, xml:tm and Term Link are not as well developed or widely used as TBX, TMX and SRX and may not have the momentum to attract people to continue developing them.

It is clear that the LISA standards or the ideas behind the standards benefit the translation industry and at the very least TBX, TMX and SRX should continue to be developed in some way.

TBX has already been approved as an ISO standard and ISO TC37 will presumably lead its future development.

The closure of LISA may give an opportunity for some consolidation among standards development. For a relatively small industry we have a lot of standards but very few people actually involved in developing them. I have been involved with the development of XLIFF since the beginning and this standard is unusual in that you have a vibrant, active and enthusiastic technical committee developing it. There have been far fewer people involved in the OSCAR standards committee at LISA. There has also been problem for some time and that is getting work done on these standards. The most recent revision of TMX was published in 2005. At the time there was a lot of discussion about TMX 2.0 and plans for a major revision but instead only minor changes were made.

I doubt if there would be many objections if one of the effects of LISA’s closure was to consolidate XLIFF, TMX and SRX. XLIFF is already capable of being used as an exchange format for translation memory which is what TMX does. Some experts have commented that one thing missing from XLIFF is an ability to list the segmentation rules. SRX would provide that. A consolidation like this would also deal with the problem of not having the people to develop the standard. Many of those involved in OSCAR are also members of the XLIFF TC. The translation industry would benefit by consolidation of these standards and I hope it is something which LISA and OASIS looks at very supportively.