# incidental to



## la_wilsen

Hello!!

The text is about the use of electronic signatures and records and it says: "A computer system that is incidental to the creation of paper records/documents"

My try "un sistema informático que queda al margen de / tiene un papel secundario ante la creación de registros/documentos en papel"

Any help, please? My translation does not sound good.

Thanks!!!


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## Jaime Bien

¿"que guarda relación con"? Espera a ver qué dicen otros.

De todas maneras, la palabra existe en español, por lo que la podrías utilizar del mismo modo:


> *incidental**.*
> * 1.* adj. Que sobreviene en algún asunto y tiene alguna relación con él.
> 
> * 2.* adj. Dicho de una cosa o de un hecho: Accesorio, de menor importancia.


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## William Stein

la_wilsen said:


> Hello!!
> 
> The text is about the use of electronic signatures and records and it says: "A computer system that is incidental to the creation of paper records/documents"
> 
> My try "un sistema informático que queda al margen de / tiene un papel secundario ante la creación de registros/documentos en papel"
> 
> Any help, please? My translation does not sound good.
> 
> Thanks!!!



It's a strange use of "incidental". The computer system can't be considered "marginal" because it does practically everything in the creation of the records/documents, from editing, formatting and storage on to control of the printer when it's printed out (the printer can't do anything by itself, of course).
I would put "un sistema informático que está implicado en la creación de ..."


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## machokrap

I think we need more context, but "papel secundario" seems plausible to me.


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## k-in-sc

It means word processing software that is* "no integral" *to the creation and storage of the documents, and so doesn't have to be verified.

 Part 11 is intended to apply to systems that create and maintain 
electronic records under FDA's requirements in Chapter I of Title 21, 
even though some of those electronic records may be printed on paper at 
certain times. The key to determining part 11 applicability, under 
Sec. 11.1(b), is the nature of the system used to create, modify, and 
maintain records, as well as the nature of the records themselves.
    Part 11 is not intended to apply to computer systems that are 
merely incidental to the creation of paper records that are 
subsequently maintained in traditional paper-based systems.

Source


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## William Stein

la_wilsen said:


> Hello!!
> 
> The text is about the use of electronic signatures and records and it says: "A computer system that is incidental to the creation of paper records/documents"
> 
> My try "un sistema informático que queda al margen de / tiene un papel secundario ante la creación de registros/documentos en papel"
> 
> Any help, please? My translation does not sound good.
> 
> Thanks!!!



I think you're right then but it would be much clearer if you had included "merely incidental" in the quote.
They must be talking about hardware like Olivetti "word-processors" which are basically fancy typewriters instead of computers (https://www.pinterest.com/pin/479633429036464237/):
    Part 11 is not intended to apply to computer systems that are 
merely incidental to the creation of paper records that are 
subsequently maintained in traditional paper-based systems. In such 
cases, the computer systems would function essentially like manual 
typewriters or pens and any signatures would be traditional handwritten 
signatures. Record storage and retrieval would be of the traditional 
``file cabinet'' variety.


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## k-in-sc

William Stein said:


> I think you're right then but it would be much clearer if you had included "merely incidental" in the quote.
> They must be talking about hardware like Olivetti "word-processors" which are basically fancy typewriters instead of computers.


No, they're not talking about old-fashioned word processors, they're talking about any computer hardware and software that is not used to store and maintain the records, as the source makes clear.


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## William Stein

k-in-sc said:


> No, they're not talking about old-fashioned word processors, they're talking about any computer hardware and software that is not used to store and maintain the records, as the source makes clear.



1) You just said it means software in post #5
2) Olivetti is contemporary and is still a big seller
3) Any hardware that can't be used to maintain records is necessarily of that type, as they make clear: it functions as a typewriter. You can call it old-fashioned if you like.

Anyway, the point is that electronic signatures are applicable only to softcopies not hardcopies (paper versions), so that hardware that is primarily used to produce hardcopies rather than softcopies is not relevant to the question of electronic signatures. Software can always be used to produce either hardcopies or softcopies, as far as I know, with the possible exception of the "software", if you want to call it that, in Olivetti word processors.


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## k-in-sc

It's not that it can't be used to maintain records, it's that it isn't used to maintain records.
Maybe Olivetti is still big in Costa Rica. ...


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## William Stein

k-in-sc said:


> It's not that it can't be used to maintain records, it's that it isn't used to maintain records.
> Maybe Olivetti is still big in Costa Rica. ...



As opposed to ultra-modern South Carolina, ha, ha! 
Anyway, you still don't get it at all, it's not a question of records in and of themselves, it's a question of paper records (hardcopy records) versus softcopy records (computer files). Hardware that only produces hardcopies is irrelevant to the question of electronic signatures. Read your own quote:
Part 11 is not intended to apply to computer systems that are 
merely incidental to the creation of paper records that are 
subsequently maintained in traditional paper-based systems. In such 
cases, the computer systems would function essentially like manual 
typewriters or pens and any signatures would be traditional handwritten 
signatures. Record storage and retrieval would be of the traditional 
``file cabinet'' variety.


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## steemic

k-in-sc said:


> It means word processing software that is* "no integral" *to the creation and storage of the documents, and so doesn't have to be verified.
> 
> Part 11 is intended to apply to systems that create and maintain
> electronic records under FDA's requirements in Chapter I of Title 21,
> even though some of those electronic records may be printed on paper at
> certain times. The key to determining part 11 applicability, under
> Sec. 11.1(b), is the nature of the system used to create, modify, and
> maintain records, as well as the nature of the records themselves.
> Part 11 is not intended to apply to computer systems that are
> merely incidental to the creation of paper records that are
> subsequently maintained in traditional paper-based systems.
> 
> Source



Nice find! Looks like you pretty much cleared this up for the OP.  As far as the spanish interpretation goes Papel secundario seems like a good suggestion to me. That's in all reality what the English text is suggesting.  It's not the primary focus, more something that one learns as a side or after affect.


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## k-in-sc

Incidental: nonessential, peripheral, unimportant, insignificant


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## William Stein

k-in-sc said:


> Incidental: nonessential, peripheral, unimportant, insignificant



Part 11 is not intended to apply to computer systems that are merely incidental to the creation of paper records that are subsequently maintained in traditional paper-based systems.

Completely wrong. That's not the point at all. The point is not that the computer system is of secondary importance to the creation of paper records, it means systems that are only used for the creation of paper records and not for computer files. This may be "tangential' because you actually have to understand the content but the text is about electronic signatures as the OP says in post 1 so it is not relevant to computer systems that create paper records like Olivetti word processors. It has nothing to with the systems being non-essential relative to the creation of paper records.


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## Jaime Bien

_William_, cómo te gusta discutir, cualquiera diría que eres español . Yo lo veo como _k-in-sc_.


> Part 11 is intended to apply to systems  that create and maintain electronic records under FDA's requirements in  Chapter I of Title 21, even though some of those electronic  records may be printed on paper at certain times. The key to determining  part 11 applicability, under Sec. 11.1(b), is the nature of the system  used to create, modify, and maintain records, as well as the nature of  the records themselves. Part 11 is not intended to apply to *computer systems*  that are merely incidental to the creation of paper records that are  subsequently maintained in traditional paper-based systems.



 Es decir, el documento se ha creado de la manera tradicional, aunque se  haya utilizando para ello un procesador de texto cualquiera de un  sistema informático (como Word), lo que sería equivalente a, en otra  época, haber utilizado una máquina de escribir o haberlo escrito a mano  con un bolígrafo. Estos sistemas que son meramente utilizados como  procesadores de texto para escribir esos documentos no se hallan  implicados, es decir: sistemas informáticos que son *meramente accesorios* (que sólo juegan un papel  secundario / que son meramente utilitarios) en la creación de documentos en papel  (tradicionales).


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## William Stein

Jaime Bien said:


> _William_, cómo te gusta discutir, cualquiera diría que eres español . Yo lo veo como _k-in-sc_.
> 
> 
> Es decir, el documento se ha creado de la manera tradicional, aunque se  haya utilizando para ello un procesador de texto cualquiera de un  sistema informático (como Word), lo que sería equivalente a, en otra  época, haber utilizado una máquina de escribir o haberlo escrito a mano  con un bolígrafo. Estos sistemas que son meramente utilizados como  procesadores de texto para escribir esos documentos no se hallan  implicados, es decir: sistemas informáticos que son *meramente accesorios* (que sólo juegan un papel  secundario / que son meramente utilitarios) en la creación de documentos en papel  (tradicionales).



That makes me, laugh, too 

Part 11 is intended to apply to systems that create and maintain electronic records under FDA's requirements in Chapter I of Title 21,

This is exactly what I said, that electronic signature regulations apply to computer systems that produce softcopies (electronic records) not hardcopies (paper records).

Part 11 is not intended to apply to *computer systems*that are merely incidental to the creation of paper records
You forgot to higlight the most important part of the sentence, "paper records". Word processing programs like Word are used to produce both electronic and paper records so that can't possibly be what they're talking about. They mean that hardware that is only used in creating paper documents is irrelevant because the regulations are about electronic signatures.

It's really very easy understand to if you just read the passage and notice the distinctions between electronic and paper documents in the context of electronic signatures (see post #1)


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## Jaime Bien

Word processing programs like Word *can be used* to produce both electronic and paper records. But when they are not integrated into the global system that manages the electronic signatures, they can only be used for the creation of paper records (although these documents were stored in the memory and not physically printed). For example, at work, I can create a document using Word in the PC at my desk and I can store this document in it, but if my PC is not integrated into the global system, I will not be able to manage electronic signatures with this document. So my computer is part of the computer systems in which part 11 is not intended to be applied to.


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## William Stein

Jaime Bien said:


> Word processing programs like Word *can be used* to produce both electronic and paper records. But when they are not integrated into the global system that manages the electronic signatures, they can only be used for the creation of paper records.



Not true. An electronic record is a computer file. You cannot possibly use Word without creating a computer file, everytime you open a new document, edit or save you are creating or modifying an electronic record. Software has nothing to do with it, and I've never even heard the term "computer system" applied to software.



Jaime Bien said:


> For example, at work, I can create a document using Word in the PC at my desk and I can store this document in it, but if my PC is not integrated into the global system, I will not be able to manage electronic signatures with this document.


  
You can create and store an electronic signature in Adobe Acrobat without being on a network and then it use it later. Networking is beside the point.

It's really very simply if you just forget about software for a second, which is a complete red herring. When has software ever been referred to as a "computer system" anyway? The article is defining the scope of the electronic signature regulations. The only thing excluded is hardware like typewriters and pens that print on paper, because paper documents have normal, physical signatures that are subject to other laws. The law mentions not only typewriters but also lab equipment that prints out rolls of paper with graphs plotted on them. They are not subject to electronic signature regulations because they only print paper documents (they merely incidential to the creation of paper documents = they are merely a tool used to create paper documents). It doesn't mean that such instruments and typewriters are in any way secondary to paper documents or less important than them, it means they are only instrumental in producing paper documents, which are irrelevant for the purposes of electronic signature laws.


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## Jaime Bien

William, más claro el agua:


> SUMMARY: The Food and Drug Administration (FDA) is issuing regulations  that provide criteria for acceptance by FDA, under certain  circumstances, of electronic records, electronic signatures, and  handwritten signatures executed to electronic records as equivalent to  paper records and handwritten signatures executed on paper. These  regulations, which apply to all FDA program areas, are intended to  permit the widest possible use of electronic technology, compatible  with FDA's responsibility to promote and protect public health. The use  of electronic records as well as their submission to FDA is voluntary.  Elsewhere in this issue of the Federal Register, FDA is publishing a  document providing information concerning submissions that the agency  is prepared to accept electronically.





> For example, if a person were to use word processing software to generate a paper submission to FDA, part 11 would not apply to the computer system used to generate the submission, even though, technically speaking, an electronic record was initially created and then printed on paper.
> When records intended to meet regulatory requirements are in electronic form, part 11 would apply to all the relevant aspects of managing those records (including their creation, signing, modification, storage, access, and retrieval). Thus, the software and hardware used to create records that are retained in electronic form for purposes of meeting the regulations would be subject to part 11.


SO, OTHER SOFTWARE AND HARDWARE (COMPUTER SYSTEMS) USED TO CREATE RECORDS THAT ARE RETAINED IN ELECTRONIC FORM NOT INTENDED TO MEET THESE REGULATIONS WILL NOT BE SUBJECTED TO PART 11.


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## William Stein

Jaime Bien said:


> William, más claro el agua:
> 
> 
> 
> SO, OTHER SOFTWARE AND HARDWARE (COMPUTER SYSTEMS) USED TO CREATE RECORDS THAT ARE RETAINED IN ELECTRONIC FORM NOT INTENDED TO MEET THESE REGULATIONS WILL NOT BE SUBJECTED TO PART 11.



We don't have to analyze the entire law and every possible exception. Anyway, this is getting off-topic, the question is the meaning of "incidental" and I believe that I have amply demosntrated that "incidental to" in the OP's question here does not mean "secondary to" or "insignificant" but rather "involved in" (implicada en) as I suggested 97 posts ago or so. I have to work now and I think that anybody's who really interested in understanding the phrase in question can understand now and anybody who's hell-bent on disagreeing will to continue to disagree but that's no longer my concern.
Have a good day!


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## steemic

The very suggestion of incidental has to imply that it is involved with or linked to something else.  I think that goes without saying.   
However that "something else" is normally of greater importance.  
If someone claims incidental expenses on an expense report for example they are referring to secondary expenses that occurred as a by-product or consequence of other more significant expenses like airfare, hotel costs, etc.  
If a computer system is incidental in the creation of paper documents it is certainly associated with their creation but more as a consequence of a larger role that the system serves.  Hence the suggestion of *secondary*.  I think that is honestly the best suggestion here.


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## k-in-sc

Agree that here incidental to = secondary to / not critical to / not central to / not integral to / etc.


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## Jaime Bien

Last try .

William, sospecho que no nos estamos refiriendo exactamente a lo mismo, que tú lo miras desde un punto de vista y yo (los demás) lo miramos desde otro.

Tu postura: "Part 11 is not intended to apply to computer systems that are merely incidental to the *creation of paper records *that are subsequently maintained in traditional paper-based system". Y por tanto para ti significa que son *los sistemas envueltos exclusivamente en la creación de documentos en papel* los que están excluidos de tener que contemplar la regulación. Para ti, estos sistemas no son secundarios en la creación de esos documentos en papel, pues son necesarios para poder hacerlo.

Mi postura (y creo que la de los demás): "Part 11 is not intended to apply to computer systems that are merely incidental to the *creation of paper records that are subsequently maintained in traditional paper-based systems*". Digamos que los documentos en papel se guardan en carpetas en armarios, son gestionados a la vieja usanza, son firmados manualmente y son enviados por correo tradicional. Luego en todo este proceso manual, poca importancia tiene el sistema informático utilizado para simplemente crearlos e imprimirlos (aunque exista una copia electrónica, para que el documento pueda ser gestionado debe ser impreso previamente en papel). Desde este punto de vista, el sistema informático utilizado para crearlos (escribirlos mediante un editor de texto) y posteriormente imprimirlos es *accesorio, secundario,* ya que la gestión (mantenimiento, clasificación, firma y envío) de estos documentos en papel se realiza manualmente y no por procedimientos electrónicos. Pues bien, estos sistemas informáticos que sólo sirven para crear e imprimir los documentos en papel (y que no han sido preparados para poder procesar los documentos electrónicamente: creación, mantenimiento, firma y envío electrónicos), lógicamente no tienen que contemplar esta regulación.

¡William, danos la razón!


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## William Stein

Here's is the phrase in question: 
: "A computer system that is incidental to the creation of paper records/documents"

Can anybody please explain how 'secondary to / not critical to / not central to / not integral to paper records, etc." would make any sense at all here?

Jaime: I don't agree that the system used to create  the paper documents could be considered secondary to them and even if it were, why would the law mention paper documents but not electronic documents according to your idea? According to my idea, the explanation is simple: systems used only to create paper documents are irrelevant to electronic signatures, which involve only electronic documents.

You have to consider Occam's Razor, too, and choose the simplest explanation over an unnessarily complex explanation of the facts (unless you simply choose to ignore the facts, as seems to be in fashion).


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## Jaime Bien

It is secondary to the managament of paper documents, because I could write them by another means different from informatic ones. It is only a tool to create (write) them.


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## William Stein

Jaime Bien said:


> It is secondary to the managament of paper documents, because I could write them by another means different from informatic ones. It is only a tool to write them.



I agree with the idea that the excluded computer systems are a tool to write paper documents = are instrumental in writing them but why even mention paper documents and not electronic documents? My idea is that the reason why computer systems that are "merely incidental to paper documents" are excluded is that they are only used to make paper records and not electronic documents (like the typewriters, pens and lab instruments they specifically mention).

Why do they mention paper documents and not electronic documents in that sentence according to your idea?


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## Jaime Bien

My idea is that the reason why computer systems that are merely incidental to paper documents are excluded is that they can't be used to manage documents electronically.


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## William Stein

Jaime Bien said:


> My idea is that the reason why computer systems that are merely incidental to paper documents are excluded is that they can't be used to manage documents electronically.



I agree with that but you're using "merely incidental" to mean "solely related to", which makes sense (as opposed to "secondary to paper documents" which makes no sense at all).


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## steemic

Once again if you refer to the above posts you will see that is not what everyone is suggesting.  We are suggesting exactly the opposite.  Incidental = secondary, consequence.  Not solely related.


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## Jaime Bien

William, there are two ideas in the sentence (and the more important idea is the first one):

1) The systems only used in the management of paper documents are not included (because they are not able to manage documents electronically).
2) In paper documents management, the systems used to write documents are just a tool, so incidental to the management itself.


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## William Stein

steemic said:


> Once again if you refer to the above posts you will see that is not what everyone is suggesting.  We are suggesting exactly the opposite.  Incidental = secondary, consequence.  Not solely related.



And that's what I'm saying is obviously wrong and I have explained why in great detail. I repeat my question. How would "secondary to" make any sense in this sentence:
Can anybody please explain how 'computer systems that are secondary to / not critical to / not central to / not integral to paper records shoud be excluded from the scope of the law?
I know you're going to say you've read and understood everything I wrote and you simply disagree but if that's really true you should be able to answer the question.


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## William Stein

Jaime Bien said:


> William, there are two ideas in the sentence (and the more important idea is the first one):
> 
> .
> 2) In paper documents management, the systems used to write documents are just a tool, so incidental to the management itself.



The sentence specifically says "incidental to the creation of paper documents" not to their management.


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## Jaime Bien

It is implicit in the context provided. And don't forget the definition  of incidental. We shouldn't redefine "incidental" to make our  interpretation has (had?) sense, but on the contrary, we should find an  interpretation according to the real definition of incidental.


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## fenixpollo

The challenge of this forum is to translate words and short phrases with only limited context. In general, if you don't understand the original sentence, it's best not to offer a translation. Although you may not understand the nature of the computer system referenced in the original sentence, the fact is that the original sentence refers to a computer system. 

Unfortunately, la_wilsen has offered very little background detail, and it's not very productive to go round in circles trying to guess at what kind of system is referred to in the original sentence. The best thing is to wait for la_wilsen to return with more information, or to accept the excellent suggestions made by machokrap and k-in-sc and move on to bigger and better things.


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## William Stein

Jaime Bien said:


> It is implicit in the context provided. And don't forget the definition  of incidental. We shouldn't redefine "incidental" to make our  interpretation has (had?) sense, but on the contrary, we should find an  interpretation according to the real definition of incidental.



But the primary meaning of incidental according to your own quoted definition is "related to"!:
*
incidental**.*
*1.* adj. Que sobreviene en algún asunto y tiene alguna relación con él.

*2.* adj. Dicho de una cosa o de un hecho: Accesorio, de menor importancia.



​

Anyway, I'm out of here. I have two gigantic rush jobs to do and I've already made my point for anybody who takes the time to read my posts.


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## Jaime Bien

Fenix, I just wanted to respond to William.

 That was my first suggestion, without more context. But the first definition also suggests secondary, accessory (necessary to do something or related to in some way, but not main).


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