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Subsidiary Reviews in the European Union

Written by JOHN BALCHUNAS and reprinted with permission from INTERCOM, the magazine of the Society for Technical Communication. Arlington, VA U.S.A.

Since the formation of the European Union (EU) in 1993, member countries have continued to develop and strengthen a single-market economy. This trend to unification is evident in the recent push for translated product documentation and labeling in EU member countries. Focused largely on health and safety concerns, the EU's industry-specific directives govern the language requirements of end-user documentation. While the overall scope of the directives varies from industry to industry, most mandate that documentation must be provided in the national languages of all member states (General information about the EU, including lists of member states, can be found on the Web at www.europa.eu.int/index_en.htm) Companies in many different industries are working at a feverish pace to produce translations of end-user documentation to meet EU deadlines, some of which are as early as December 2003. As a result of these deadlines, technical communicators in affected industries- such as medical devices and home appliances-are quickly overcoming many traditional translation hurdles. Documentation departments have formed solid relationships with translation agencies, streamlined documents to facilitate translation, and developed corporate level translation policies. However, challenges remain for documentation departments and translation agencies worldwide. One of these challenges is the process of successfully coordinating an in-country subsidiary review, which consists of providing an electronic copy of translated documentation to corporate subsidiaries for linguistic review. Unlike traditional quality control reviews, which focus on the technical accuracy of the text, in-country subsidiary reviews focus on the accuracy of the translation. If your company is doing business in the EU or plans to do so in the future, you'll want to become familiar with subsidiary reviews. Although not specifically required by the EU, they are a common practice and one that will prove valuable in ensuring accurately translated documentation.

In-Country Subsidiary Reviews

Most technical communicators are familiar with the practice of performing quality control reviews on documentation before finalizing the text. Similarly, in-country subsidiary reviews offer corporate subsidiaries a valuable opportunity to comment on the linguistic accuracy of a translation. Translation agencies often employ native speakers of a target language to ensure that the text is properly localized, but even the best translation team is occasionally unfamiliar with some preferred terminology used in the field.

Once the subsidiary review process is in place, the translation agency can manage it. However, if the process is not properly set up, the reviews can be a headache. Truculent reviewers, review technicalities, and logistical nightmares can make the process hard to handle for technical communicators and translation agencies. By resolving issues beforehand, you can ensure a smooth review process.

Building Confidence

One of the biggest challenges a documentation team may encounter in the beginning stages of any review process is establishing a healthy working relationship with the reviewers. This task can be exceptionally difficult when factoring in a translation agency and time and cultural differences. Yet this relationship is paramount to gaining the subsidiaries' trust and confidence in both the review process and the overall quality of the translations. Several steps can enhance the relationship from day one:

1. Ensure that subsidiary reviewers understand their role in the translation process. Uninformed reviewers are often tempted to re-translate the documentation; instead, they should simply review the translation from a technical standpoint.
   
2. Encourage correspondence between the translation team and the subsidiary reviewer. It is beneficial for a translation team to correspond with future reviewers throughout the translation process on questions of terminology and product functionality. Building rapport between the teams at an early stage can help calm the anxiety of the subsidiary reviewers.
   
3. Write clear work instructions for the subsidiary reviewers. Well-written instructions tell reviewers everything they need to know about a project. The instructions should be written before the translation process begins; they will help the translation agency, translators, and reviewers better understand the entire project. The instructions could include a description of how to review a document, project and product history, review deadlines, and instructions for how to return the document.
   
4. To minimize potential problems, consider translating work instructions into the target languages. While all translation reviewers should understand both languages very well, providing instruction in the reviewers' native language further reduces the likelihood of misunderstanding.

Finding the Best Review Method

Considering the number of authoring tools available in the technical communication workplace, it is a challenge to find a suitable method for reviewing translated documentation. Electronic review methods typically work best for subsidiary reviews because of the distances between the home office, subsidiaries, and translation agency. In general, these methods need to meet some basic requirements:

• They should require little training time for the reviewer.
  
• They should allow the reviewer to easily comment on the translation.
  
• They should allow the translation agency to easily find and incorporate changes and comments made by the reviewer. Translations can be reviewed using Microsoft Word, Microsoft Excel, and Adobe Acrobat. The use of these and other, more specialized, review options, such as working directly in Translation Memory (TM) files, should be discussed with translation agencies and prospective reviewers at the start of a translation project.

Microsoft Word-or Excel-Mediated Reviews

The biggest advantage of using Microsoft Word or Excel for reviewing translations is that these programs are everywhere. Subsidiary reviewers are highly likely to be familiar with both of these programs, thus minimizing training time. With the Track Changes feature, both programs allow subsidiaries to easily annotate the translations. However, depending on the original authoring tool, these programs do not always provide an accurate, print-ready representation of the translated documentation.

Adobe Acrobat-or Acrobat Reader-Mediated Reviews

PDF reviews using Adobe Acrobat or Adobe Acrobat Reader are also highly effective, especially when it is important to provide the reviewer with a final, print-ready version of the translated documentation. Most subsidiaries should be able to open a PDF file for review in either Acrobat or Acrobat Reader. However, commenting on the translation can be difficult unless reviewers can use Adobe Acrobat's Note feature.

Translation Memory-Mediated Reviews

Although more difficult to implement, Translation Memory (TM) tools offer another potentially valuable method for reviewing translations. Almost all translation agencies use TM tools to leverage or "recycle" previously translated text from project to project. However, these tools either are stand-alone applications (such as SDLX or D?ja vu) or they create tagged files in a familiar interface (such as TRADOS). In both cases, they can require significant training for the subsidiary reviewers. When set up properly, Translation Memory-mediated reviews can be very efficient in the long run. However, the investment in time, software, and, most important, training can make implementing this option a challenge.

All these options should be discussed with the translation agency before launching a translation project. Combining several review methods allows for a very effective document review.

Receiving Timely Reviews

Like any review process, subsidiary reviews take time. Considering European holiday schedules, work hours, and the reviewer's normal job functions, lengthy subsidiary reviews can potentially delay project timelines. Often, reviewers are not trained linguists but rather service and sales personnel in the target country. While they may have a good command of the English language and of product functionality, they may not have adequate time to devote to the task. Fortunately, a number of steps can be taken to mitigate this risk:

1. Give subsidiaries ample notice of upcoming translation projects. Subsidiary reviewers may understand their role in the review process, but they may not be familiar with your project schedules. When you are beginning a translation project, send a project launch memo to the subsidiary reviewers, informing them of the project.
   
2. Set clear deadlines. Ensure that any work instructions that accompany translations for review clearly indicate when subsidiaries should complete the review process. Establishing reasonable and fair deadlines can be tricky; they should be discussed with potential reviewers and translation agencies.
   
3. Inform subsidiaries of the consequences of late reviews. Deadlines depend largely on corporate policies and EU directives; monitoring timelines will require key management support. Slippage can mean that a product is not sold in the target country or that translations are accepted "as is," without subsidiary review.
   
4. Inform project team members and managers at the beginning of a project of the time that will be required for translation. Often the time allowed for technical communication-related activities is minimal. Project managers need to allow enough time for a comprehensive subsidiary review.

Forging Ahead

Once a subsidiary review is under way, track such specifics as document length, review methodology, and turnaround time. Consider surveying subsidiaries on their satisfaction with the quality of translations, the review process, and review methods. This feedback can be valuable in several ways:

• Project statistics can be used heuristically to more accurately predict the length of time required to review documentation.
  
• Feedback can be used to improve the review process.

In-country subsidiary reviews allow companies to ensure the accuracy of their translations. One consequence of the review process is that technical communicators in EU-regulated industries gain more familiarity with the complexities of writing for the international community.