Do We Really Need Translation Standards After All? 2

A Comparison of US and European Standards for Translation Services

by Gérard de Angéli

Translation Standards (US & European)

Until recently, the translation industry did not have a standard covering all aspects of the translation process. (There were only some partial guidelines or standards: see Note (5)).

However, standards specific to our industry have now been developed. This is a major change: ISO 19001 Standard requirements for instance were general and applicable to all sectors (manufacturing or services), whereas these new standards cover the specific processes we are familiar with (translation, revision…).

Rather than describing these new standards in detail, I will first review European Standard EN 15038, with which I have some first-hand experience in terms of assessment and compliance, providing an overview of the Standard and raising issues with regards to its application.

Then I shall review US Standard Guide F 2575 – 06 based on documentary analysis as I have had no first-hand experience in applying the US Guide to my own practice, identifying the pros and cons and comparing these two Standards.
European Standard EN 15038:2006

BSI states: “EN 15038:2006 specifies the requirements for the translation service provider with regard to human and technical resources, quality and project management, the contractual framework, and service procedures. (Note: it does not apply to interpreting services).

The standard offers a description and definition of the entire service and at the same time, it is designed to provide translation service providers with a set of procedures and requirements to meet market needs.” (3)

We provide below the Standard’s contents, as provided on the British Standard Institute web page (https://www.bsi-global.com/en/Shop/Publication-Detail/?pid=000000000030122045):

Read Also: Do We Really Need Translation Standards After All? 3

(© BSI 2007 Extract from BSI Website)
General review and appreciation

The above list may seem impressive, and indeed it is!

After a year or so spent assessing my own practice as a translation service provider and making my own processes compliant, and based on my experience in the quality assurance field, my opinion is that this standard encompasses our activity quite extensively and provides many requirements.

List of requirements

A standard specifies a list of requirements to meet in order to conform to the standard (“Thou shalt not …).

Close review of its content show that this Standard includes about 95 individual items, each stating a different requirement. Some of these ‘content’ requirements (by content I mean requirements specifying required characteristics of translation product/process) also include documentation requirements.

For instance, Section 3.2.1 (of Chapter 3 Basic requirements) entitled Human resources management states that:

– “Translators shall have the professional competences as specified in 3.2.2”

But, in the same paragraph it also states:

– “The TSP (Translation Service Provider) shall have a documented procedure in place for selecting people with the requisite skills and qualifications for translation projects’.

In ordinary language, it means that there are two requirements: you must have a procedure in place (i.e. ‘A specified way to perform an activity’, (6)), and secondly, you must have a written document, stating the purpose and scope of activity, what shall be done, by whom, when, where and how, with what means, and how it is controlled and recorded.

For instance, as a freelance translator or translation agency (TSP), if you are to provide translation from English into five other target languages and want to prove (your client or any other third party) compliance with this standard, you will need:

1. to produce a document (‘procedure’) describing the way you have selected qualified translators (either as employees of your TSP company, or freelance subcontractors) for a particular project.

2. to apply your procedure and show evidence (record) that this particular translator had the stated required competences to do the particular job he/she was assigned to.

Of course, all documents must be kept up to date and amended according to any changes in your activities/processes.

Table 1 below shows the distribution of requirements among the various sections/areas of the Standard.

Table 1: Distribution of European EN 15038 requirements by Standard section/area

Referring back to the three types of standard as stated earlier (namely Product, Process (incl. human resources) and Management, this standard is clearly process- and management-oriented rather than strictly product- or people-specific. It focuses on processes rather than product/service outputs. You will not find any specifications with regards to qualification testing/certification of translators or detailed scale-to-rate final product quality/compliance.
European Standard EN 15038 Issues

Compliance with this standard raises a certain number of issues, especially with regards to the relationship between freelancers and translation agencies.
Subcontracting

For instance Paragraph 5.4.3 Revision states that “The TSP shall ensure that the translation is revised’ (and further that “The reviser shall be a person other than the translator…”).

If you act as the TSP (i.e. the main and direct contracting party with the client), then your final translation product shall be revised prior to delivery to the client.

If you work as a subcontractor to the TSP (e.g. as freelancer), you might either have your translation job revised by another freelancer before delivery to the TSP, or submit your translation unrevised to your TSP. In this case, the Standard clearly states that “Where a TSP chooses to engage a third party to carry out a translation project or any part thereof, the TSP shall retain the responsibility for ensuring that the requirements of this standard are met with respect to that project or any part thereof.”

In my experience, this is going to be a significant issue in our industry, as most agencies do not have their translations revised before delivery to the end-user/client! At least this has been my experience…
Cost

The related issue is cost: TSPs will have to devise a special marketing and selling concept to justify higher costs for added value/quality services.
Third-party Certification or Declaration of Conformity

“Certification is when an accredited third party visits an organization, assesses their management system and issues a certificate to show that the organization abides by the principles set out in the standard, so following industry best practice” (BSI).

This is called “third-party” certification, which is of course the main (and very profitable) business of certification bodies.

But an alternative solution is available to deal with compliance. It is called Declaration of Conformity (the term ‘self-certification’ shall be avoided to prevent confusion with Third-party certification). This procedure has been used by many manufacturers around the world in many fields and extensively in Europe with regards to the CE conformity marking procedure (7). This should be seriously considered by TSPs, who would have to follow strict rules in accordance with specific ISO Standards requirements (8) for this type of process.

Claiming that one’s translation service complies with EN 15038 requirements with no real documented quality management system should be avoided, as the client may ask you to prove it (and rightly so) and … bring you to court on grounds of false advertising!