Slide1: EN 15038 European Standard — — Practical Remarks on Certification Andrzej Nedoma, Jurek Nedoma, Grzegorz Baster Berlin June 2007


Slide2: The EN 15038:2006 standard versus other standards; complementary character of EN 15038:2006 compared to ISO 9001:2000 Present state of certification of the EN 15038:2006 certification procedures throughout Europe 3. Self-declarative certification model versus third-party auditing and certification – comparison of approach, benefits, in-house efforts and costs 4. Benefits for translation agencies that are EN / ISO certified 5. Approach of certifying bodies in individual countries 6. Practical remarks and recommendations for the owners of translation agencies – methodology of gap analysis, role of external consultants? 7. Recommended steps to elaborate, implement, improve and maintain a useful EN 15038 management system 8. Criteria for choosing the certifying body


Slide3: Standards focused on the target text quality SAE J2450 – Society of Automotive Engineers LISA QA Model – Localization Industry Standard Association ATA Accreditation / Certification Program – American Translators Association GB/T 19682-2005 – 翻译服务译文质量要求 – Target text quality requirements for translation services


Slide4: Standards focused on service requirements (probably the base for the future ISO standard) ASTM F2575-06 – Standard Guide for Quality Assurance in Translation GB/T 19363.1-2003 – 翻译服务规范 第1部分:笔译 – Specification for translation service – Part 1: Translation. EN 15038:2006 – Translation services – service requirements Only in the EN 15038:2006: Conformity assessment and certification based on this standard are envisaged


Slide5: The ISO 9001:2000 standard is not addressed to any specific branch of industry or services. It is a general regulation that is valid for any branch. To the contrary – the EN 15038:2006 standard is addressed specifically to translation service providers. EN 15038:2006 does not require the implementation of the ISO 9001:2000 quality management system.


Slide6: It is required by the EN 15038:2006 standard to have a “quality management system in place that is commensurate with the size and organisational structure of the TSP”. Of course, the quality management system implemented and certified according to the ISO 9001:2000 standard, which is commonly known and reputable – meets the requirement of the quoted Clause 3.4 of EN 15038:2006.


Slide7: Legal base – standard approval The European standard EN 15038:2006, prepared by the Technical Committee CEN/BT/TF 138 „Translations services”, was formally approved by the European Committee for Standardisation (CEN) on 13. April 2006 in three official versions (English, French and German) as: „Translation services – service requirements”; „Services de traduction – Exigences requises pour la prestation du service”; „Übersetzungs-Dienstleistungen – Dienstleistungs-anforderungen”, respectively.


Slide8: Versions in any other languages translated under the responsibility of a CEN member into its own language and notified to the Central Secretariat have the same status as the official versions. Withdrawal of conflicting national standards Conflicting national standards had to be withdrawn at the latest by November 2006. This relates e.g. to: the Italian UNI 10547:1996 – Definizione dei servizi e delle attività delle imprese di traduzione ed interpretariato, the Dutch – ATA Taalmerk (1997), the German DIN 2345:1998 – Übersetzungsaufträge, and the Austrian ÖNORM D 1200:2000 – Dienstleistungen – Übersetzen und Dolmetschen – Übersetzungsleistungen – Anforderungen an die Dienstleistung und an die Bereitstellung der Dienstleistung and ÖNORM D 1201:2000 – Dienstleistungen – Übersetzen und Dolmetschen – Übersetzungsleistungen – Übersetzungsverträge.


Slide9: Members of CEN /CENELEC obliged to adopt the EN 15038:2006 standard In total 30 countries: 27 EU countries (Bulgaria after 01-01-2007) + Iceland + Norway + Switzerland Austria Belgium Cyprus Czech Republic Denmark Estonia Finland France Germany Greece Hungary Ireland Iceland Italy Latvia Lithuania Luxembourg Malta Netherlands Norway Poland Portugal Romania Sweden Switzerland Slovakia Slovenia Spain United Kingdom


Slide10: The observance of EN 15038:2006 standard regulations is voluntary Formally the Translation Service Providers (TSP) are not obliged to implement the standard. However, individuals (freelancers) or organizations (translation agencies) providing translation services can implement the standard by a fully voluntary decision.


Slide11: Ways to inform the market players about the fact, that the TSP decided to follow the EN 15038:2006 standard regulations Self-declaration Self-declaration registered by DIN CERTCO Certification by an independent third party (the accredited certifying body)


Slide12: Meaning of the term „accreditation” general - accreditation of the certifying body specific - accreditation to the defined standard Present offer for translation agencies EN 15038:2006 standard „non-accredited certification” performed by the accredited certifying body Misleading announcements


Slide13: Approach Benefits The translation services provider (TSP) unilaterally declares the observance of the standard regulations in company’s activity. - The declaration is fully voluntary. - No verification procedure of such statements is foreseen. - An official (often misleading) certificate can be obtained from DIN CERTCO. - The procedure requires actual review of the overall activity of the company. -The certificate issued basing on an objective third-party audit really distinguishes the TSP. The TSP should pass an objective audit performed by an independent certifying body (third-party) to confirm the observance of standard regulations in company’s activity.


Slide14: In-house efforts Costs Practically no special efforts are necessary. In the case of simple self-declaration – no costs are borne. In the case of DIN CERTCO certification: – the registration fee is ca. 200 €, – the annual fee for subsequent years does not exceed 100 €. Preparations to the third-party audit requires real efforts of the entire staff, which leads to the self-improvement of TSP’s organisation. The fees of the certification body constitute 1,500-8,000 € (depending on the country, size) Recommended consulting services cost ca. 2,500-25,000 € (depending on the country and the size of the applicant company).


Slide15: The first EN 15038:2006 certified translation companies in Europe Glossima & Wehrheim, Thessaloniki, Greece certification body: EUROCERT SA, Athens, Greece accredited by the Εθνικό Σύστημα Διαπίστευσης A.E., Hellenic Accreditation Council (ESYD) Interlingua Language Services GmbH, Vienna, Austria certifying body - Österreichisches Normungsinstitut (the Austrian Standards Institute) accredited by the accreditation body at the Bundesministerium fuer Wirtschaft und Arbeit (Federal Ministry of Economics and Labour), Vienna, Austria


Slide16: EN 1538:2006 certificates issued for LIDO-LANG in English ----------- and in Polish ----------


Slide17: The main certifying bodies offering EN 15038:2006 certification in Europe Bureau Veritas Greece – in co-operation with the Πανελλήνιος Σύνδεσμος Μεταφραστικών Επιχειρήσεων (Hellenic Association of Translation Companies – HATC) United Kingdom – in co-operation with the Association of Translation Companies ATC Spain – in co-operation with the Agrupación de Centros especializados en Traducción (Spanish Association of Translation Companies – ACT) Poland – in co-operation with the Polskie Stowarzyszenie Biur Tłumaczeń (Polish Association of Translation Agencies – PSBT) Sweden – on individual initiative of the applicant


Slide18: The main certifying bodies offering EN 15038:2006 certification in Europe National standard institutes Austria – Österreichisches Normungsinstitut (ÖN) - in co-operation with the WKO Fachverband Druck Arbeitskreis Sprachdienstleister France – Association Française de Normalisation AFNOR – in co-operation with the Chambre Nationales des Enterprises de Traduction CNET Finland - Suomen Standardisoimisliitto SFS ry and its certification body – Inspecta Sertifiointi Oy - in co-operation with Suomen Käännöstoimistojen Liitto SKTOL


Slide19: The main certifying bodies offering EN 15038:2006 certification in Europe National standard institutes (continued) Italy – Organismo di Normazione e Formazione nel Commercio, Turismo e Servizi UNITER – in co-operation with the Federazione Nazionale Centri di Traduzione e Interpretariato FEDER.CEN.TR.I Germany – Technischer Überwachungsverein TÜV Süd - in co-operation with the Qualitäts-Sprachendienste Deutschlands QSD


Slide20: There are two fundamental reasons. The first – to differentiate ourselves from other competitors; the second – to improve our own mode of operation [Source: An Italian consulting company]


Slide21: Short-term benefits: refreshing and rejuvenating effect of gap analysis as a critical review of the present organisation; source of new ideas for improvement going beyond the standard; confirmation for the staff as well as for customers that the agency meets the requirements formulated by the translation experts across Europe. [Source: Cox, Chris: The Translation Service Provider’s Guide to BS EN 15038 ed. BSI Business Information (2006) ]


Slide22: Long-term benefits: after full implementation, the standard delivers a “fitness for purpose” platform and a starting point for further development; right to advertise the agency’s expertise, supporting confidence in rendered services especially within customer relations that are conducted via the Internet, only possibility to use the requirements of the standard when formulating safe contract conditions; [Source: Cox, Chris: The Translation Service Provider’s Guide to BS EN 15038 ed. BSI Business Information (2006) ]


Slide23: Long-term benefits (continued): clear formulation of the customer’s special requirements that are contradictory to the code of best practice; attaining the status of “due diligence” in the case of any defence in a court action; the ability to add further standards and other national and inter-national specifications, e.g. ISO 9001:2000, ISO 14000:2000, etc. possibility to use the standard in all trading operations of the agency. [Source: Cox, Chris: The Translation Service Provider’s Guide to BS EN 15038 ed. BSI Business Information (2006) ]


Slide24: Methodology The methodology of certification is very similar in all CEN countries: Initial self-assessment of the applicant using a questionnaire Detailed certification audit 3 years period of certificate validity Annual auditing Re-assessment audit after 3 years Fees Extremely different depending on the country Ranging from ca. 1,500 – 5,000 € (for similar size of applicant company) Neglecting better preparation of ISO-certified applicants


Slide25: Strong points of the auditors Excellent knowledge of ISO 9001:2000 standard strongly influencing auditor’s behaviour during EN 15038:2006 audits Weak point of the auditors Limited knowledge of the specific character of translation industry Misinterpretation of certain clauses of EN 15038:2006 Incorrect formulation of certain items in the intial questionnaire


Slide26: Future trends for certifying bodies Training of a special group of auditors assigned for certification in translation industry Gathering experience from the first certification audits Re-formulation of initial self-assessment questionnaires Combined certification to ISO 9001:2000 and EN15038:2006 standards Application to the national accreditation bodies for accredited EN15038:2006 certification


Slide27: One decisive condition that is inevitable: a consciousness of the top management of the company Positive role of the gap analysis A comprehensive review of the entire company Source of self-improvement Better identification of all employees with the company as a whole


Slide28: Role of an external consultant To understand better the real meaning of the standard clauses To arrange a training for applicant’s staff (if required) To avoid unnecessary self-obligations of the applicant To facilitate preparation of all necessary documentation To perform the internal „pre-assessment” audit To help the applicant in choosing the optimal certifying body To assist the applicant’s representative in his/her direct contacts with the auditor To participate in the certification audit on behalf of the applicant company, etc.


Slide29: Reasons, why hiring a consultant is beneficial Excellent knowledge of the requirements and recommendations of the standard Knowledge of the external auditor’s expectations and behaviour Ability to formulate the procedures and other required documents combining the applicant’s present customs with strict clauses of the standard Ability to limit the applicant’s obligations to the minimum required by the standard Ability to speak the external auditor’s „certification slang” Experience in selecting the optimal certifying body


Slide30: Each certifying body has its own procedures for applicants. The following steps are common for all these certifying bodies. Purchase a legal copy of the standard (the national or the international version of EN 15038:2006) Analyse thoroughly the entire standard, individually or with a consultant’s help Standards are subject to copyright protection. Therefore any copying of the standard is illegal. It is necessary to distinguish clearly the difference between “shall” and “should” clauses – i.e. obligations and recommendations, respectively


Slide31: Elaborate the gap analysis, i.e. define what is missing in order to satisfy the standard requirements, individually or with a consultant’s help. Solve the problems realised during the gap analysis, eliminate discrepancies with standard requirements, amend the existing methods of operation. This is the crucial element of the process. Without proper knowledge of the gaps, the implemented system will not be approved by the external auditor. Therefore, contracting a consultant seems to be very helpful, time-saving, and much safer. “Translate” the existing methods of operation into the “language” of standard requirements, amending them if required by the standard.


Slide32: Edit the written procedures required by the standard, exactly corresponding with the company’s internal modes of operation and fulfilling the standard requirements. Select a certifying body. Hiring a consultant for this step is time-saving and avoids the unnecessary, excessively strict, written formulation of self-obligations, which are not required by the standard. Copying the procedures and quality manual is not recommended because each company has its own, internal habits and there appears a risk that the auditor can realise that the “copied procedures” are not followed. The auditors should be reliable partners, understanding the specific character of this branch.


Slide33: Pass successfully the certification audit performed in translation agency office Deliver the system documentation to the certifying body for their in-house review. Conclude a contract with the chosen certifying body. On request. Participation of a consultant (on TSP’s behalf) during the certification audit is very useful because any negative auditor’s observations can be quickly and professionally commented on by the consultant, who uses the same “standardisation language”.


Slide34: General remarks It is important for the procedures to describe your real processes, customs, and behaviours of your employees in order to avoid any “revolutionary changes” caused by the non-controlled implementation of the standard requirements. In our own case, thanks to the implementation of the XTRF management system as well as using the consulting services of EUTECert Co. Ltd., the EN 15038:2006 certification did not take more than 4 weeks.


Slide35: General terms of certification (how many man-days of audits per year; how often is the re-assessment) Reputation of the certifying body. Experience in the field of translation services (i.e. their auditors should be reliable partners, understanding the specific character of this branch). The auditors should understand the specific character of this branch – in order to avoid unnecessary discussions with non-professionals. Experienced customers know the reputation of the different bodies rendering certification services. Overall cost (certification audit, annual surveillance audit(s), re-assessment audit, travel, accommodation, etc.) Proper choice of the certifying body can help you to save a lot of time and money


Slide36: Thanks for your kind attention! To get more info – please visit our booth #7 www.eutecert.eu www.lidolang.com