I think there is a general agreement that labelling is the least effective method of risk control and how much it reduces is debatable; but Content Deviation#7 does not prohibit you from using information from safety to reduce risk.
Why do you provide users with a user manual in the first place - isn't it to reduce the risk by ensuring proper use (among other things)?
Training may not necessarily be better, but it may be another option. Some people prefer watching/listening rather than reading, so training may be more effective in conveying the information for proper use than a manual.
here's an excerpt from the Team NB Position Paper regarding Content Deviation #7:
"ISO 14971 (Annex J) and ISO/TR 24971 describe ‘information for safety’ as instructions for use, warnings, required maintenance, etc.. ‘Information for safety’ comprises instructions of what actions the user can take or avoid in order to prevent a hazardous situation from occurring. On the other hand, ‘disclosure of residual risk’ has the objective to inform users of remaining risk inherent to the use of the medical device, and concerns the risks remaining after all risk control measures have been taken.
Any information for safety comprising instructions of what actions the user can take or avoid in order to prevent a hazardous situation from occurring may be considered a risk control measure. As required by Essential Requirement 13.1 of Directive 93/42/EEC (respectively ER B.8 of 98/79/EC) it may be considered as a risk control measure. The information includes the instructions for use, labels, etc.. Since ‘safe use’ is related to risk control measures, the Medical Device Directives do not deviate in that regard from EN ISO 14971. Any effects on risk reduction are to be documented by the manufacturer in the risk management file.
‘Disclosure of residual risk’ should be conducted in compliance with EN ISO 14971 Clause 6.4, 6.5 and 7. The manufacturer shall not claim a reduction to the probability of harm when disclosing residual risk."