tekom edoc guideline strategies and legal aspects for ... tekom edoc guideline – strategies and...

Schmeling + Consultants GmbH Heidelberg

www.schmeling-consultants.de Telefon +49 (0) 62 21 / 58 50 47-0

Presentation

Sarah Fancy and Roland Schmeling

tekom eDoc guideline – Strategies and legal

aspects for electronic documentation

Stuttgart, 2017-10-24

[email protected]

Our focus today

tekom eDoc Guidelines

A model for implementing electronic media

Modules for analysis

Modules of a media concept

Success factors

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eDoc

eDoc Guideline

• Challenges the notion of paper first

• Over 20 experts from a range of branches

• Interaction on the European level in Brussels

• Background and EU legal aspects of providing user

information electronically, aspects of a media concept and

concrete recommendations for implementation with

examples (52 pages)

• First comprehensive document on the topic

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eDoc: Motivation

Reasons for printing instructions in industrial companies

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Tekom-Richtlinie eDoc, 2016, page 8

translated by author

Law requires paper form

Contract requires paper form

Tradition

Physical conditions require paper form

Electronic documentation not accessible

Customers expect paper

Conversion to electronic docu not yet implemented

Paper form for production reasons

Cost

eDoc: Motivation

Use of electronic instructions

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Supporting a digitalization strategy

Uses for customers

Search functions

Availability

Context dependency

Procedures in video

Interlinking media

Customizability

Interactivity

Connectivity

Customers expect digital media

Costs decrease when printed media is reduced

eDoc

Information for use in the product lifecycle

• Media-relevant characteristics of the product

• Product lifecycles

• User groups and use cases

Economic view

• Printing costs (printing, paper, material, transport/logistics, waste, storage)

• Costs for electronic information (e.g., IT infrastructure)

User perspective

• Availability

• Usability

• Acceptance

Ecological perspective

• Paper recycling

• Electronic scrap

Designing the media concept

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eDoc: User perspective

Availability, usability and acceptance

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Aspect Approach Source

Availability Risk analysis Per EU Directive 207/2012: the risk

analysis must cover all media,

which includes printed instructions,

because the availability of printed

instructions is not higher than

electronic instructions per se.

Usability Recognized criteria For instructions in general:

IEC 82079-1:2012;

for electronic and multimedia

information:

ISO/DIS 9241-11:2015-11

Acceptance Empirical analysis IEC 82079-1:2012, Annex E


Suitable for the task

Suitable for the communication goal

Suitable for perception and

understanding

Self-descriptiveness (of software)

Conforms to expectations

Promotes learning

Controllability

Suitable for exploration

Error tolerance

Individualizable

Motivates users

User preference

Requirements for the usability of instructional media

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Sources:

IEC 82079-1 Preparation of

instructions for use

ISO 9241-11 Ergonomics of human-

system interaction

ISO 14915 Software ergonomics for

multimedia user interfaces


Interviews (written, oral, group interviews)

Usability testing

Self-assessment and checklists

Assessments, checks by experts, and certificates

Findings from independent prices

Complaint management, hotlines, customer service information

Methods for determining acceptance as per IEC 82079-1:2012

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Quelle: tekom Richtlinie eDoc; von: BMW Group, 01//2016

Could you imagine calling up the content of your owner‘s manual only in digital

form in the future ?

1215

1986

613

211

1079

N =

eDoc: State of the art Techn

olo

gie

s fo

r cre

atio

n

• XML

• Metadata

• Editor

• System for managing and providing content D

eliv

ery

fo

rmat

• Enclosed

• Embedded

• Mobile

• Online

• Augmented

• Virtual

Dis

pla

y d

evic

es

• Laptop or desktop computer

• Smartphones and tablets

• Integrated screens

• Integrated displays

State of the art for providing electronic information

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Interactions, formats, media, access locations

Goal: facilitate line of

argument on the European

level

eDoc: Concept

Factors that influence the concept

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Product

Information-related

properties: e.g.,

functions that need

explaining, displays

User groups

Information-related

properties, e.g.,

language, previous

knowledge, media

competency,

expectations

Use cases: Time,

requirement of

information,

environmental

conditions, access to

information, risks

Norms

Information-related

requirements: e.g., from

safety norms and legal

regulations of the target

markets

Manufacturers

Information-related

conditions: e.g.,

production conditions for

instructions and media,

formats of source data

Differentiated Information and media concept

Supply chain

Information-related

conditions and

requirements: e.g.,

logistics, technology for

providing electronic

information, contracts

eDoc: Concept

Procedural model from eDoc

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Analysis

Product and

options to display

information

(6.2.1)

Legal requirements (6.2.2)

Module 1:

Clarify

contractual

requirements

Module 2:

Product

liability

requirements

Module 3:

Product safety

regulations in

target markets

Module 4: Comparing the requirements and provisions

and clarifying what is in the contract

User groups

(6.2.3)

Use cases

(6.2.4)

Media concept

Definition of a

content-media matrix and

interconnection matrix

(6.2.5 and appendix B)

Evaluating

the failure

risks

(6.2.6 and

appendix C)

Testing the

media

concept

(6.2.7)

Implementation, improvement

and internal documentation

(6.2.8)

Clear, strategic objectives

Internal stakeholders included

High level of information quality

Specifications for new media

User acceptance Methodic standardization

Success factors

eDoc: Concept


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Analysis

Product and

options to display

information

(6.2.1)


User groups

(6.2.3)

Use cases

(6.2.4)

Media concept



(6.2.8)






Success factors

Module 1:

Clarify

contractual

requirements

Module 2:

Product

liability

requirements

Module 3:

Product safety

regulations in

target markets



Definition of a




Evaluating

the failure

risks

(6.2.6 and

appendix C)

Testing the

media

concept

(6.2.7)

eDoc: Concept – Analysis

Purpose and functions

Intended user tasks

Display

Size and resolution

Touch function

Ergonomics

Location on device

Storage

Connection/linking

Price

Product properties and important information properties

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Tasks and responsibilities

Statistical data

Assumed linguistic and reading ability

Physical requirements

Work environment

Access to information

Technical competence

Procedures

Material

Mechanical, electrical,

electronic, hydraulic, ...

Software

Product-specific competence

Training content

Product observations

Task analysis

Describing user groups

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Questions

• Description: What are the main

properties?

• Markets: Are there important

issues specific to certain

markets?

• What consequences are their

for information development?


Property Description Specifics

(markets,

segments)

Consequences for

information development

Tasks and

responsibilities

Installing a window, adjusting,

check whether it closes,

assembly, etc.

In Europe, mainly

through unions

Assign information about

roles/unions, perhaps

separate information

products

Work

environment

and tools

Team (typically 2-4 installers),

building site, unheated

Usually simple professional

tools, no special tools

— List any special tools,

options for ordering

Competency

(and

qualifications)

Various unions: carpenters,

window fitters, or non-

professional […]

— Eliminate specific carpentry

terminology

Information

access

No electronic access can be

assumed

Switzerland:

Laptops being

used, more in

planning

Printed information

required

… … … …

Describing user groups – example: Installer

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Use cases as the central issues of the media concept

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Example of user case

(Source: tekom Guide Mobile Documentation, 2013)

Use cases are even more important

when distributed to different media

formats

eDoc: Concept


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Success factors

Analysis

Product and

options to display

information

(6.2.1)


Module 1:

Clarify

contractual

requirements

Module 2:

Product

liability

requirements

Module 3:

Product safety

regulations in

target markets



User groups

(6.2.3)

Use cases

(6.2.4)

Media concept

Definition of a




Evaluating

the failure

risks

(6.2.6 and

appendix C)

Testing the

media

concept

(6.2.7)



(6.2.8)


Product liability

Standard is accuracy: safety

standards users expect

Awareness of information on residual

dangers

Proof of effectiveness required

Take forseeable use into account

Contract law

What is usual, if not in contract

State of the art

Intended use as listed in contract

Legal situation

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Case law for product safety

Nikon Digital camera LG Potsdam,

Judgement from June 26, 2014, Az. 2

O 188/13

Does not clarify what „provided“

means

Product safety EU: Guidelines

Following slides


Blue Guide 2016

Footnote 100:

Unless otherwise specified in specific

legislation, whilst the safety information

needs to be provided on paper, it is not

required that all the set of instructions is

also provided on paper but they can also

be on electronic or other data storage

format. However, a paper version should

always be available free of charge for the

consumers who request it.

Machinery directive 2006/42/EG

No statement about the form of the

instructions

Guide to application of the MD, § 255:

general consensus is to print

information that is relevant to health

and safety because it cannot be

assumed that users have access to a

reading device

Electronic information is desired:

Advantages are recognized

Legal requirements: Product safety (EU)

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EMC Directive 2014/30/EU

Harmonization as part of the New

Legislative Framework: instructions

required

No requirements for the delivery format of

the instructions

Preliminary guidelines-- is not state of the

art

User has to be able to use the device

without any further searching for

information, like going to the internet

Electronic media and hyperlinks are not a

sufficient alternative to paper

Example with a PC: Instructions on DVD

are sufficient if the computer has a DVD

drive

Low-voltage directive 2014/35/EU

Harmonization as part of the New

Legislative Framework: instructions

required

No requirements for the delivery format of

the instructions

Draft Guidance Document: Not every set

of instructions must be on paper

If the device is resold, the dealer must

make sure that each product includes

instructions

Legal requirements: Product safety (EU)

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Medical device – with recommended implications to other segments

Goals: Environment, costs; level of safety cannot decrease

Exclusively for professional users

Information for patients cannot be provided electronically

Documented risk assessment

Provide electronic instructions for use in all member states in which the product is

being sold

Exceptions only after risk assessment

Providing on storage devices: Must also be available on a website

Correct design and usability (it has to work)

Proven validation and testing

Display of information on the product does not affect safety

A system that the manufacturer can use to indicate changes in the user instructions

If changes are relevant to safety, every user must be informed

Availability of electronic instructions for use

Products with expiration date: up to 2 years after the last product has expired

Products without expiration date: up to 15 years after the last product is manufactured

Legal requirements: Product safety EU – EU regulation 207/2012

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eDoc: Concept


Analysis

Product and

options to display

information

(6.2.1)


Module 1:

Clarify

contractual

requirements

Module 2:

Product

liability

requirements

Module 3:

Product safety

regulations in

target markets



User groups

(6.2.3)

Use cases

(6.2.4)

Media concept

Definition of a




Evaluating

the failure

risks

(6.2.6 and

appendix C)

Testing the

media

concept

(6.2.7)



(6.2.8)






Success factors

eDoc: Concept – Media Concept

Table for required information – Example of Wi-Fi router

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Use case Information required Medium Comments

Preparing the connection

(done by provider)

– – Created by the service

provider and given to

technicians

Connection (consumer) Safety information Printed instructions, included* –

Overview of all parts,

cables, and accessories

Printed instructions, included* –

Instructions for connecting Printed instructions, included* –

Video on youtube.com –

Configuration (consumer) Selecting a language Embedded help –

Setting a password Embedded help –

Log-in info to connect

devices to Wi-Fi network

Embedded help –

Printed instructions, included* Only preconfigured login

Page that user can print User-configured log in

Disposal (consumer) Notes for WEEE

(Directive 2012/19/EU on

waste electric and electronic

equipment)

Label With symbol (crossed out trash

bin)

Printed instructions, included* Explanation of the symbol

*Also in online help and as a downloadable PDF

Embedded help: all required help is integreated into the software GUI


Content-media matrix – example of Wi-Fi router

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Content Medium 1:

Included printed

instructions

Medium 2:

Embedded help

Medium 3:

Downloadable PDF

Medium 4:

Video

Safety information X – X –

Overview of all parts,

cables, and

accessories

X – X –

Connection diagram X – X –

Connection instructions X – X X

Selecting a language – X X –

Log-in info for

connecting devices

– X X

Only preconfigured

login

–

Notes for WEEE

(Directive 2012/19/EU

on waste electric and

electronic equipment)

X – X –


Example of default risks

Hampered access to information due to user’s lack of knowledge and experience

with the medium

Hampered access to information due to issues in the user‘s environment (light)

Hampered or no access to information due to lack of usability of the medium, for

example: it can‘t be used with work gloves

Hampered access to the means of displaying the information (like smartphone)

Non-availability of the medium (e.g., printed information locked away in a cupboard)

Non-availability of required hardware

Non-availability of required software

Non-availability of required network

Medium isn’t working (functional defect)

Forbidden to use medium

Evaluating default risks – requirement from 207/2012

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Evaluating default risks – Method 1: comparing media

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Measures that decrease the risk to an acceptable level to be able to

use the medium are important

Default risk

type

Medium 1:

Complete

printed

instructions,

350 A4 pages,

paperback

Medium 2:

Printed and

laminated

quick guide

Medium 3:

Downloadable

PDF

Medium 4:

Video

(Internet)

Steps

Wear and tear

of the medium

High risk Medium risk – – Suitable print

and paper

quality,

protective

container,

protective

envelope

Updateability Can only be

replaced via on-

site service or

delivery (1

week)

Can be

replaced by on-

site service or

delivery (1

week)

Any time Any time Issue date on

the printed

instructions,

replacement of

instructions with

bigger updates


Evaluating default risks – Method 2: analyzing use cases

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No. Use case Default risk of the

medium, causes

and likelihood

Possible

consequences

Goal and

actions

1 Restart after temporary

downtime of control

software

Electronic

instructions not

available during

software downtime

Not relevant for

safety

Print instructions

for restarting after

downtime and

make available as

download in online

help

2 Error message: diagnose

error in material flow in

machine and eliminate

issue

Printed instructions

not available (lost,

mislaid, locked in a

storage unit):

possible to likely

Users try to solve

problem on their

own; information on

safety during error

rectification not

available. Releasing

blockage without

stopping machine

extremely

dangerous.

Availability of the

information on the

machine must be

ensured.

- Steps included

in electronic

error reporting

- Warning sign

on all access

points to

material flow


Testing the media concept: Usability test

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Tester mounted the foot

incorrectly on the standpipe

Tester doesn‘t realize the cable

has to hang down

In the video, add a down arrow

next to the cable

Test: Low-language video instructions Example from the Multimedia Funktionsdesign project at

the Furtwangen University

eDoc: Concept


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Analysis

Product and

options to display

information

(6.2.1)


Module 1:

Clarify

contractual

requirements

Module 2:

Product

liability

requirements

Module 3:

Product safety

regulations in

target markets



User groups

(6.2.3)

Use cases

(6.2.4)

Media concept

Definition of a




Evaluating

the failure

risks

(6.2.6 and

appendix C)

Testing the

media

concept

(6.2.7)



(6.2.8)






Success factors

Success factors: recommendations

Product management 1 with lots of standard products printing costs

Product management 2 with high-priced individual products: customer loyalty; alternatives to print

Management: Digitalization, reducing overall costs and risks. Also: How secure is the information

Legal department: Lack of safety (product safety, liability, contract law)

Editorial department: Creation effort and effective processes

Head of production: Number of printed user guides and different formats

Marketing: Producing attractive media economically

Logistics/supply chain: costs

Training department: usability

IT: Feasability, infrastructure, security

Define strategic goals und integrate internal stakeholders

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Success factors: recommendations

Putting existing information into an app isn‘t enough

Example: Investing in modularization, classification and terminology is vital so that

users aren‘t just searching, but also finding what they need

No acceptance without information quality

No half measures: Only use media that you know something about!

Managing information quality and increasing user acceptance

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Contact Schmeling + Consultants GmbH

Wieblinger Weg 17

69123 Heidelberg

E: [email protected]

T: +49 (0) 62 21 / 50 58 47-0

Roland Schmeling


T: +49 (0) 62 21 / 50 58 47-2

Sarah Fancy


T: +49 (0) 62 21 / 50 58 47-0

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tekom edoc guideline strategies and legal aspects for ... tekom edoc guideline – strategies and...

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