Do We Really Need Translation Standards After All?

A Comparison of US and European Standards for Translation Services

n June 2006, ASTM International (originally known as the American Society for Testing and Materials) issued the Standard Guide for Quality Assurance in Translation (1). Simultaneously, the CEN (European Committee for Standardization, comprising standardization bodies of 27 member states of the European Union) published European Standard EN 15038:2006 Translation Services - Service requirements (June 2006) (2).

To date (December 2007), only five national bodies have officially published this standard as part of their national catalogue of applicable standards, namely Germany, France, UK, the Netherlands, and Austria.

Readers are invited to respond, submit questions and raise issues on the TJ's blog.

Since we will be talking about standards (in translation), let us have a look first at what standard means.

Ordinary language

In ordinary language, standard used as a noun can have the following meanings (Oxford Dictionary):

1. A level of quality or attainment.
2. A required or agreed level of quality or attainment.
3. Something used as a measure, norm, or model in comparative evaluations.
4. (Standards) principles of honourable, decent behaviour.
5. A military or ceremonial flag.
6. An upright water or gas pipe.
7. A tree that grows on an erect stem of full height.
8. A shrub grafted on an erect stem and trained in tree form.

For the purpose of our discussion, 3 meanings seem relevant:

1. Level of quality
2. Required or agreed, and
3. Measure for comparison purpose

[Interestingly enough, the modern word 'standard' comes from the Old French 'estendart' (a military or ceremonial flag). And it is amusing to find that translation companies claiming that their services comply with translation standards display their new officially approved status (certificate) using a ... flag!

Below are a few typical 'Flags' of these modern translation warriors:

Etc...]

So a standard refers to quality, and as a translator/translation provider, do you care about quality?

You certainly would do when a client complains that in the last English to French translation of a Marketing Report, "outstanding orders of XYZ Proprietary Drug" was translated as "commandes exceptionnelles pour le médicament XYZ" (instead of "commandes en souffrance" - back orders! (Real life story heard recently at a meeting of translation professionals in Strasbourg).

But which quality?

Final product quality? Translator's quality? Quality of your final revision/check procedure? Or quality of your processes for selecting translators and/or subcontracting, or managing the whole translation process, etc.?

This leads to two other interesting ideas:

FirsT, agreed or required quality: now how far you go about stating required quality level with your clients? The client quoted above (pharmaceutical) might have told you that "The document contains medical terms and it is very important that the translation of such terms be accurate." Well, this would seem like a pretty basic (and obvious) requirement as regards medical translation (or actually any other specialized field!). You would expect that a translation of a medical document be accurate, would not you? But most of the time the agreed/required level of quality will not be further defined or formally stated. This is due to the fact that most clients view translation services as a pure commodity.

The second interesting point is measurement and comparison. How can I measure the quality of my translations? Are Robert's translations better than mine?

At this point of the discussion you might say that so far we have been stating the obvious!

Maybe we need the help of the 'pros' now.

So let us hear what the standardization experts have to say about it.

Techno language

The British Standard Institute (BSI) defines a 'standard' as:

"A document, established by consensus and approved by a recognized body, that provides, for common and repeated use, rules, guidelines or characteristics for activities or their results, aimed at the achievement of the optimum degree of order in a given context" (3).

Now we know that a standard is a document, including:

Guidelines or

Characteristics

That cover activities or results, and

Let us get into a little more detail as regards the definition of a standard.

According to the ISO (International Organization for Standardization):

"Standards can be broadly sub-divided into three categories, namely product, process and management system standards. The first refers to characteristics related to quality and safety for example. Process standards refer to the conditions under which products and services are to be produced, packaged or refined. Management system standards assist organizations to manage their operations. They are often used to help create a framework that then allows the organization to consistently achieve the requirements that are set out in product and process standards." (4)

Does this help?

We now know that there are three kinds of standard:

1. Standards for products (What BSI calls "results")
2. Standards for processes (What BSI calls "activities"), and
3. Standards for management system

Now how does this apply to translation?

1. The product is the document or software delivered to the customer
2. Processes cover the way the translator does the translation (its competences and methods) and/or the way the translation project manager manages translation jobs
3. The management system of the freelance translator/translation agency

Before we review the present translation standards, let say a word about previous standardization/compliance programs for translation companies.

As you are probably aware, the manufacturing industry and other services worldwide have been involved in quality management and improvement programs and campaigns of all kinds from the early seventies, in an effort to compete with the Japanese industry (initially in automotive industry)

One of the 'tools' or methods used to initiate and drive such a process, especially for large industrial firms in relation to their subcontractors, has been the compliance with and certification to the ISO 9000 Series of Standards (9003, 9002 and 9001) conducted in many firms, and presently supplemented by the ISO 14000 Series of Standards on environmental management.

Numerous service companies have also been involved in this standardization process, including some translation companies.

Finding out how many translation companies in the world are ISO 9001 registered proved to be a hard task: searching on the website of the leading French certification body (AFAQ) returned three translation service providers as being ISO 9001 registered in France over a total of 60,000 registered companies. The UK BSI site could not be searched by sector and the German DKSCERT.com server returned 6 German translation services providers as being ISO 9001 certified.

So it would seem that currently very few translation companies are ISO 9001 registered.

Going back to the distinction between the three types of standards, we can say that the ISO 9000 Series Standards are clearly process and quality management system-oriented standards. And as we will see, the new European Standard on translation services does not differ much from these Standards.

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.

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 (http://www.bsi-global.com/en/Shop/Publication-Detail/?pid=000000000030122045):

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!

How many TSPs are EN 15038 registered?

This is a hard one to answer because there is no central register of certifications/declarations, due to the fact that there are so many certification bodies worldwide. A quick search on Google (as of 05.09.07) returned the following results:

The large number of links found on the German pages is partly due to DIN-CERTCO (the German standardization national body) policy regarding what they call the 'special registration' service. As the DIN-CERTCO website explains (9):

You will find the whole registration process explained on the relevant web page, along with the list of DIN-EN Registration Mark holders (about 250, mostly German, TSPs). If you think your services comply with EN 15038 requirements, you may consider registering with DIN-CERCO. It will cost you €57, which is a cheap price to pay to have a nice flag on the home page of your website! Of course, this does not attest to your compliance with EN 15038 requirements. At most, it attests to your ... €57 payment to DIN-CERTCO and ... to the great marketing skills of Germans! To the best of my knowledge, none of the other large standardization bodies in Europe (BSI and AFNOR) offer this service.

Standard scope

"(It)..also includes a list of specification parameters that shall be considered before work begins." (10)

Note: The analysis I provide below was carried out on the basis of documentary review alone and not by any attempt to conduct an assessment of Guide's requirements.

Content summary

1. Scope
2. Referenced documents
3. Terminology
4. Significance and use
5. Introduction to Translation
6. Selecting a Translation Service Provider
7. Description of Project Phases
8. Specifications Phase
9. Production Phase
10. Post-Project Review
11. Keywords

General appreciation and review

My opinion is that the US Guide is more of a set of guidelines to follow for both the end-user (client) and the TSP, than stricto sensu a standard stating the requirements for the TSP to comply with in order to obtain external certification. I doubt that a certification body could devise a certification scheme for say third-party certification based on this Guide. The document details factors, rather than requirements, which have to be taken into account to get optimum results in translation tasks, again from both end-user and TSP points of view. It applies as much to in-house translations as to translations performed by external TSPs.

I find this joint approach (end-user) quite refreshing and very promising indeed, as it aims to provide the client with guidelines and involve it in the specification process. Which is, in my experience, very often a weak step in the translation process supply chain (see also below comments about Section 8). In contrast, EN 15038 provides very few useful guidelines for the end-user; in fact it is not intended for end-users (EN 15038 Introduction says: "This document sets out the requirements relating to translation providers"). This is probably a weakness of the European Standard.

As regards definition of terms, Translation Service Provider has been retained in both standards. The US Guide uses the term Editor while the European Standard uses the term Reviser, and introduces the notion of third-party reviewer (a "person assigned by the requester or supplier to evaluate a completed translation for quality or end-user suitability"), which is a useful addition.

What I liked

Overall, I very much appreciated the practical tips and tools provided in the following sections:

• Section 6 (Selecting a TSP): this section addresses issues in the selection of a translator, and applies equally well to the selection process from the end-user (client) perspective to the decision process of a TSP when selecting freelance sub-contractors. I found the specific system and tools provided in this Section and Appendix more operational than the requirements set out in EN 15038, and I intend to use them in my own practice.
• Section 8 (Specifications Phase): again this section provides many useful leads and guidelines to designing translation specifications, which is often a very weak link in the translation process chain, as stated above. Poor quality in translation is often due to a lack of specifications stipulated by the end-user.

The above comments indicate that both standards provide useful and complementary guidelines: while the EN 15038 Standard may provide a more detailed specification of the TSP quality system and translation management framework ('System Standard'), the US Guide provides more practical 'how-to' advice and application tools.

At this point in the discussion, the reader may ask him/her self: is this for me? What benefits can I expect from it?

My own conviction is that it will eventually modify both client-TSP and TSP-translator relationships.

For instance, a translation company wishing to make its organization comply with the Standard's requirements will require its own subcontractors to demonstrate compliance as well.

Compliance benefits

Working according to the Standard requirements and the Standard management system will provide the TSP with the following benefits:

• It will give the TSP a unique opportunity to position its services on the market, and have them singled out against the competition with added selling points, provided it is backed up by a genuine translation management system and ... an effective advertising strategy!
• Any genuine effort to comply with the Standard requirements will bring about greater organizational effectiveness; and establish a continuous improvement process in TSP's operations. For instance tracking and compiling complaints and non-conformities (either internal or external) for traceability purposes will induce corrective and preventive measures for a greater long-term effectiveness.

In a next article, we will review and discuss the essential components of a compliance program, with real-life stories from TSPs that have been through the process.

Notes

1. F 2575 - 06 Standard Guide for Quality Assurance in Translation, ASTM International, published June 2006. The Guide was issued under the jurisdiction of ASTM Committee F15 on Consumer Products and is the direct responsibility of Subcommittee F15.48 on Translation Services. Can be purchased and downloaded from http://www.astm.org/
2. EN 15038:2006 Translation Services - Service requirements. http://www.cen.eu/catweb/03.080.20.htm
3. http://www.bsi-global.com/en/Standards-and-Publications/How-we-can-help-you/Customer-Services/Glossary/
4. http://www.standardsinfo.net/isoiec/aboutstd.html
5. German standard entitled Translation Contracts Ref. DIN 2345 :1998, which was used as a basis for the newly published European Standard EN 15038:2006.
6. As defined in Standard ISO/DIS 8402: Quality management and quality assurance vocabulary
7. See CE Marking Handbook: A Practical Approach to Global Safety Certification, by David Lohbeck. Boston: Butterworth-Heinemann, 1998(Published in French by Dunod, Guide du Marquage CE, Paris, 1999 (translation: Gérard de Angéli)).
8. Namely: ISO/CEI 17000:2004, Conformity assessment - Vocabulary and basic principles. EN 45014:1998 General criteria for supplier's declaration of conformity. ISO/CEI 17050-1:2004 Conformity assessment - Supplier's declaration of conformity Part 1: General requirements. ISO/CEI 17050-2:2004 Conformity assessment - Supplier's declaration of conformity Part 2: Supporting documentation.
9. http://www.dincertco.de/en/competencies/registrations/translation_services/index.html
10. Extract from ASTM Standard Guide for Quality Assurance in Translation F 2575-06, Section 1 Scope.