We are occasionally challenged on why we say that instructions must be supplied in paper form. This has been discussed a number of times at the ATEX Standing Committee Working Group in Brussels. The latest was in response to a paper from Orgalime (the European Manufacturers' Association) requesting that electronic versions of instructions should be acceptable. This was discussed at a meeting on 16 December 2009 and the outcome was that the instructions must still be provided in paper form but that electronic versions could also be made available.
The minutes of the meeting are not as clear as would be the case if the reader had been present and had access to the Orgalime proposal, but they are reproduced here as the authority for stating the requirement for instructions to be in paper form. Specifically, the reference is to the Guidance document for the Machinery Directive (which had only just been issued at the time of the meeting), since there is no equivalent text in the Guidelines to the ATEX Directive.
Extract from the Minutes of the Meeting of the Standing Committee Working Group held on 16 December 2009 at Brussels
Format of the documentation required by (among others) the ATEX Directive
The Chairperson reported on the final version of Guidelines to the new Machinery Directive 2006/42/EC : it dealt with "Instructions" at §254 and §255 and re-affirm that "all health and safety related instructions must be supplied in paper form", even it recognized that "it is often useful for the instructions to be made available in electronic form and on the Internet as well as in paper form".
The NETHERLANDS thought that the end-user should have the documents in paper form.
DENMARK agreed with the NETHERLANDS and not on the ORGALIME proposal.
FRANCE supported the NETHERLANDS and DENMARK.
The Chairperson proposed to follow for ATEX the same indications for Machinery and to take apart the ORGALIME paper as such, but recognising its importance for further horizontal discussions with other Directives as LVD, also taking into consideration alignment exercise to the New Legislative Framework.
This was agreed.