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SPECIAL REPORT No 9/2006

concerning translation expenditure incurred by the Commission, the Parliament and the Council together with the institutions’ replies

(pursuant to Article 248(4), second paragraph, EC)

(2006/C 284/01)

TABLE OF CONTENTS

ABBREVIATIONS

Institutions’ replies

ABBREVIATIONSCIEQ Interinstitutional Committee for the Evaluation of External TranslationsCRE Compte rendu in extenso (detailed record of the debates at the Parliament’s plenary sessions)DG Directorate-GeneralDG A III Directorate A III (Translation and document production) of the Secretariat-General of the CouncilDGT Directorate General for Translation of the CommissionEP European ParliamentEPSO European Personnel Selection OfficeEU-15 languages Official languages of the 15 EU Member States prior to enlargementEU-10 languages Official languages of the 10 enlargement countriesFTE Full-time equivalent (a measurement equal to one staff member working a full-time work schedule for one year)ICTI Interinstitutional Committee for Translation and InterpretationISC Inter-Service Consultation (consultation between Commission Directorates-General)MEP Member of European ParliamentOJ Official Journal of the European UnionSGC Secretariat-General of the Council

EXECUTIVE SUMMARY

INTRODUCTION

Legal framework

Organisation of the translation services of the EU institutions

Audit scope and approach

OBSERVATIONS

The procedures applied to ensure that translation demands are met and unnecessary translations are avoided

Internal guidelines governing translation requests

The capacity to meet translation demand

The evolution of the number of pages translated

Table 1

Translation volume per target language (in thousands of pages)

Practical measures taken by the institutions to contain translation volume

Commission

Parliament

Council

Quality control

The controls to ensure translations are of adequate quality

Timeliness and other elements of client satisfaction

The cost and the efficiency of translations

The cost of translation

Cost calculations

Table 2

Full cost of internal translations

Table 3

Full cost of external translations

Table 4

Estimated full cost of translation; internal and external translation

Cost analysis

The efficiency of the translation process

Table 5

The applicable translation deadline

Forecasts of demand

Adherence to tabling deadlines

Planning

Efficient use of internal and external resources

Pre-processing

The translation units’ working methods

Outsourcing

Table 6

Outsourcing percentages in 2003, 2004 and 2005

Productivity

Table 7

Average number of pages translated per translator (FTE)

Commission

Parliament

Council

Monitoring of the translation process using performance indicators

Interinstitutional cooperation

CONCLUSIONS AND RECOMMENDATIONS

The procedures applied to ensure that translation demands are met and unnecessary translations are avoided

The procedures applied to ensure that translations are timely and of adequate quality for their purpose

The cost and the efficiency of translation

This Report was adopted by the Court of Auditors in Luxembourg at its meeting of 6 July 2006.

For the Court of Auditors

Hubert WEBER

President

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(1)  Generally English, French and German.

(2)  Council Regulation No 1 of 15 April 1958 determining the languages to be used by the European Economic Community (OJ 17, 6.10.1958, p. 385/58), as amended.

(3)  Spanish, Czech, Danish, German, Estonian, Greek, English, French, Irish, Italian, Latvian, Lithuanian, Hungarian, Maltese, Dutch, Polish, Portuguese, Slovak, Slovene, Finnish, Swedish. Since 18 June 2005 Irish has been the 21st official EU language, although certain effects of Council Regulation (EC) No 920/2005 (OJ L 156, 18.6.2005, p. 3) have been postponed until 1 January 2007.

(4)  In particular, documents published in the Official Journal of the European Union (19, 20 or 21 official languages, due to derogations concerning the use of Maltese and Irish) and documents sent to a Member State or to a person subject to the jurisdiction of that Member State (language of the State concerned).

(5)  The Translation centre in Luxembourg mainly relies on translation by freelance translators. The centre employs about 80 (in 2004) staff translators, who are mainly occupied with revision of freelance translations for the agencies and to a limited extent with translation tasks for other institutions.

(6)  Each department consists of between three and six units, specialised by policies (or domain); 77 units in total.

(7)  This figure includes outsourcing ordered by DGT, but not by other DGs for which no reliable and exhaustive figures are available.

(8)  Harmonised definition: 1 500 printed original text characters (source language), without blanks. For modified versions of existing texts, DGT counts the number of modified characters and multiplies this number by a certain percentage (50 % for internal translation and 30 % for freelance translation) in order to account for the additional work of integrating the modified parts into the original text. The Parliament uses a slightly different method, counting the number of characters of the whole modified paragraph, without adding 50 %. The resulting number of pages of each document is rounded up to the unit.

(9)  The official production figures of the Council were adapted by the Court to make them comparable to those of the other institutions.

(10)  See Annex I, footnote 9.

(11)  In its preliminary draft budget for 2006, the Commission states that ‘non core documents can be assessed against real needs in accordance with the Decision of 26 May 2004 on the supply and demand for translation (SEC(2004) 638)’.

(12)  See Annex I, footnote 9.

(13)  The number of pages translated provides comparable data for all the institutions but differs slightly from demand because of the requests turned down by the planning units and time-lags between request and delivery. The reported figures do not include grey translations or direct outsourcing, which is particularly significant at the Commission but for which there are no exhaustive figures available.

(14)  The procedural languages of the Commission are English, French and German.

(15)  Advisory Committees, Management Committees and Regulatory Committees, regulated by Council Decision 1999/468/EC of 28 June 1999 laying down the procedures for the exercise of implementing powers conferred on the Commission (OJ L 184, 17.7.1999, p. 23), replacing Council Decision 87/373/EEC of 13 July 1987, (OJ L 197, 18.7.1987, p. 33).

(16)  For example, documents destined for publishing or legal texts require better-quality translations (and thereby more resources) than documents for internal use.

(17)  CIEQ: Comité Interinstitutionnel d’Evaluation de la Qualité des Traductions Externes.

(18)  See recital 14 of Council Regulation (EC, Euratom) No 1605/2002 of 25 June 2002 (OJ L 248, 16.9.2002, p. 1).

(19)  In 2004 and 2005, the costs were significantly higher, as explained in paragraph 53, but these years were characterised by a lower efficiency because of the transition from a system with 11 to one with 21 languages.

(20)  Human Resources Management, Training, Finance, etc.

Source: Court of Auditors.

(21)  Human Resources Management, Training, Finance, etc.

Source: Court of Auditors.

(22)  Human Resources Management, Training, Finance, etc.

Source: Court of Auditors.

(23)  For the new languages, the price difference ranges from 15 % for Lithuanian to 38 % for Latvian. The average price difference is about 12 % (see Table 4) which is partly explained by the different contractual conditions. In particular the Parliament’s contractor is obliged to accept translations and has to work within very short deadlines in the case of the translation of written questions.

(24)  A tabling deadline is the minimum incompressible time allocated to a translation service to issue a requested translation.

(25)  The volume of work necessary to translate a document depends on a number of factors including the number of words that need to be translated (pages may contain texts of different length; only the amendments to a previously translated text need translation, etc.), the technical difficulty of the document and the availability of translated source or reference text.

(26)  After deduction of the time spent by secretaries on activities unrelated to the translation process.

(27)  European Commission, DGT, Translation Directorate, Evaluation Report of the Telework Pilot Project in the Translation Service, Brussels, 6 October 2003.

(28)  CRE = ‘Compte rendu in extenso’: a detailed record of the debates, representing about 18 % of the Parliament translation volume in 2003 to 2005.

(29)  The EP's political groups sometimes contract freelance translators directly if the planning unit rejects their requests (exceeding their weekly quota of 15 pages).

(30)  See also PriceWaterhouseCoopers, Comité Economique et Social (CES) & Comité des Régions (CdR), ‘Analyse comparative de la productivité des départements de traduction des institutions européennes’, Bruxelles, 4 août 2000, p. 24: ‘Il est à noter que la productivité d’un traducteur d’un établissement privé tourne aux environs de 8 à 10 pages par jour sans tenir compte de la production via “Translation Memory” (une page correspondant à 350 mots)’ (350 words = 2 100 characters = 1,4 standard pages).

(31)  Council: until 2004 (included) EU-15 languages only.

Source: Court of Auditors.

(32)  Within the English department, for instance, the productivity in the first half of 2004 of the busiest unit was 65 % higher than the productivity of the unit with the lowest workload.

(33)  DGMA, Plan d’action pour la modernisation administrative du SGC (PAMA), 30 May 2002, section 11: Réforme de la DG A III.

(34)  However, the Commission made almost no use of the list and organised its own call for tenders.

(35)  At a variable cost of 40 euro per page.

(36)  Taking into account only the variable costs of freelance translation, estimated at 40 euro per page.

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ANNEX I

THE PROVISIONS APPLYING AT THE COMMISSION, THE PARLIAMENT AND THE COUNCIL

Commission

Parliament

Table 8

Types of documents translated by the European Parliament

Council

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(1)  Rules of Procedure of the Commission, C(2000) 3614 (OJ L 308, 8.12.2000, p. 26).

(2)  These notes record all decisions adopted by the Commission during the meeting (summary note in the oral procedure) or during the day (day note for the other procedures).

(3)  Judgment of the Court of First Instance, of 19 July 1999, Case T-188/97, Rothmans International BV versus Commission.

(4)  European Commission, Note of the Secretary-General for the attention of Directors-General and Heads of Services, SEC(2003) 795, 10 July 2003.

(5)  Standard Rules of Procedure — Council Decision 1999/468/EC — Rules of procedure for the ... committee (OJ C 38, 6.2.2001, p. 3).

(6)  European Commission, Secretariat-General, Task Force Future of the Union and institutional questions, Director, Note for the attention of Mr Madelin, Director General of DG SANCO, 23 June 2004, TFAU/2 — RH — nb (2004) D/6980 5/1208 — A/DOS 6242).

(7)  The 20 categories of the May 2004 Communication covered 64 % of the translations in 2004 and 72 % in 2005 versus 34 % in 2003. The main categories in 2005 are: legislative proposals and autonomous acts (36 %), State aids and competition procedures (10 %), communications from the Commission (7 %) and tendering procedures (6 %) and web pages (4 %).

(8)  Council Decision of 22 March 2004 adopting the Council's Rules of Procedure (2004/338/EC, Euratom) (OJ L 106, 15.4.2004, p. 22).

(9)  The Council's core documents are: draft legislation at certain milestone stages; agendas for the Council; ‘A’ item notes and their addenda; documents for adoption or discussion by the Council agenda; opinions of the legal service; Council minutes; Council replies to European Parliament written questions and oral questions with debate; declarations by the Presidency on behalf of the Union; press releases for sessions of the Council; written procedure telexes; manuals which are intended for use by national departments in Member States; European Council Presidency conclusions.

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ANNEX II

THE METHOD DEVELOPED BY THE COURT TO ESTIMATE TRANSLATION COST

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(1)  The pension contributions borne by the Commission were estimated at 16,5 % of the gross salary or twice the contributions paid by the officials.

(2)  The correction factor to be applied to the page count of each sampled document in order to make the documents comparable with those of other institutions is equal to the ratio between the number of characters (or, in case the document is a new version of a document already translated, the number of modified characters marked up by 50 % as DGT does for internal translations) without blanks divided by 1 500, and rounded up to the unit, on the one hand, and the number of physical pages, on the other.

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PARLIAMENT'S REPLIES

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COUNCIL'S REPLIES

GENERAL REMARKS

The General Secretariat of the Council (GSC) welcomes the first audit on translation expenditure in some of the EU institutions and acknowledges its usefulness. It would point out that changes to aspects which were criticised in the course of the audit have already been implemented or are under active consideration in the Language Department.

The GSC would nevertheless like to stress that, faced with the major challenge of enlargement, it put in place for its entire structure a controlled approach, which was endorsed at the highest political level in 2002, and which made it possible to limit the budgetary impact of enlargement on its administrative costs.

Specifically, in the area of translation, whereas an extrapolation of the approaches adopted for previous enlargements would have resulted in an increase in staff numbers in the Language Department of approximately 765 new officials, the controlled approach referred to above will ensure a drastic reduction in overall figures when these measures are fully operational. At the end of the current period of adaptation and adjustment, the GSC will have fewer translators for a Union consisting of 25 Member States (551) than it had for a Union of 15 Member States (578).

This result has been made possible inter alia by limiting translation to the documents deemed essential to the political and legislative process (the so-called core documents), by implementing an in-depth rationalisation of the translation services, and by adopting guidelines on the drafting, content, register and length of Council documents. In doing so, the GSC has set the path for other institutions to follow.

The GSC acknowledges that, as a consequence of this approach, it now faces a problem of overcapacity in the EU-15 language units, but it stresses the transient and non-structural nature of this situation, which, in its view, must be evaluated from a dynamic point of view, duly taking into account the undeniable middle- and long-term benefits which will result in terms of controlling administrative expenditure.

The GSC also points out that, as the last link in the legislative chain prior to approval and publication of legislation in 20 languages, the Council, together with the European Parliament as regards co-decisions, must ensure that legislation adopted by the Council is of the highest quality as repeatedly demanded by the Member States. This is also true for the Council's political texts.

The quality control procedure necessary to ensure such quality and consistency naturally leads to additional costs. Unlike other institutions which can use the services of freelance agencies extensively for certain documents in order to reduce costs, this avenue is not open to the GSC, as in-house translation is the best and most cost-effective way to ensure such quality. The need for high quality texts for publication has, of course, a major impact on the cost of translation in the Council.

The GSC is however tackling this problem of overcapacity in a proactive manner and within a policy-mix addressing simultaneously all the aspects of the problem. In addition to the fact that translators or secretaries who left the nine EU-15 language units (other than English and French) after 2002 have not been replaced, Translation Department staff are actively encouraged to apply for vacancies in other DGs and directorates. A special redeployment programme, which includes identification of adequate posts, training for new functions, and motivation for change, is being set up.

Moreover, the GSC is participating actively in the interinstitutional ‘Workload balancing’ project as a net contributor and is also considering interinstitutional mobility and other possible measures provided for by the Staff Regulations.

The GSC is therefore confident that it will successfully remedy the weaknesses highlighted in the report, in particular those of a transitional nature, and that it will efficiently fulfil its mission within the limits set for its operations.

COMMENTS ON THE FINDING OF THE COURT

EXECUTIVE SUMMARY

INTRODUCTION

OBSERVATIONS

CONCLUSIONS AND RECOMMENDATIONS

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(1)  Non-core documents.

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COMMISSION'S REPLIES

EXECUTIVE SUMMARY

INTRODUCTION

OBSERVATIONS

CONCLUSIONS AND RECOMMENDATIONS

Recommendation

The Commission agrees with the recommendation of the Court of Auditors to streamline procedures for requesting translations in DGs and services and will establish rules/guidelines concerning translation of non core documents in the context of a forthcoming update of the translation strategy.

Recommendation

The Commission notes the recommendation of the Court of Auditors to establish an action plan to increase awareness and foster interest from the Community's translation activity in the EU-10 Member States and other candidate countries but points out that it has taken steps to prepare the translation markets in the acceding countries by increasing awareness and fostering interest in the Commission's translation activities: it established facilities in the representation offices in the EU-10 Member States before their accession and recently also in the EU-2 acceding countries. These are pursuing active contacts with translators' professional organisations, universities and media in the respective countries and. The Commission's ‘Visiting translator scheme’ has been extended to universities in all of these countries, including Bulgaria and Romania. Professional visits have been organised from these countries to the Commission and special efforts were made to enhance media coverage on — and professional interest in — the translation activity via the visits of the Director-General of DGT to Bulgaria and Romania in early 2005.

98.   Recommendation

The Commission welcomes the recommendation of the Court of Auditors to establish Service Level Agreements with users of translation services. Such Service Level Agreements for the translation of guides for DG SANCO and DG EMPL have already been established: these DGs have made a full evaluation of their needs for the whole year, DGT has offered linguistic advice in the drafting of the originals, and a calendar for the translation of the texts has been agreed.

Recommendation

The Commission doubts the value added of the regular use of satisfaction surveys. Nevertheless, it is currently examining the most appropriate ways to measure service quality. In addition, feedback is received regularly and followed-up.

Recommendation

The Commission agrees with the recommendation of the Court of Auditors to perform regular random quality checks. It plans, as part of its total quality management efforts, to introduce a system to define, monitor and document its quality control operations more systematically. A more systematic approach including sample checks will be carefully considered in the context of a more global analysis on quality and quality measurement which is currently being undertaken.

101.   Recommendation

The Commission accepts the recommendation of the Court of Auditors to monitor the level of direct outsourcing and ‘grey translations’ and is launching a survey to quantify the magnitude of these grey translations and direct outsourcing more precisely. Conclusions from this survey will feed into the preparations of an update of the translation strategy for 2007 and beyond.

Recommendation

The Commission accepts the recommendation of the Court of Auditors to ensure adequate management information on the cost of translation activities and is currently updating its cost-calculation and monitoring system, in line with the methodology applied by the Court of Auditors, as part of its regular management information reporting.

Recommendation

The Commission accepts the recommendation of the Court of Auditors with respect to strengthening future translation planning by its services and points out the efforts which have been taken in this respect (see point 105 above).

The Commission supports interinstitutional cooperation and also accepts the recommendation to address direct outsourcing and to extend the pilot project on interinstitutional workload balancing. However, it considers that an interinstitutional billing system would entail an administrative burden which would be disproportionate to any possible benefits.

108.   Recommendation

The Commission accepts the recommendations of the Court of Auditors relating to further improvements of the translation process and most of those have already been implemented: best practices are issued regularly in relation to use of modern technology; new translators adopt immediately these best practices and use extensively (100 %) IT translation tools. Concerning the integration of computer tools, this is an ongoing project both for administration and translation tools. The automation of pre-processing was one important step in this direction.

The Commission is currently increasing the number of teleworkers in DGT from 100 to 200.

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