Friday, April 22, 2011

Case Study: Material Handling Equipment

To break up the monotony of standards jargon, I thought it best to provide a recent example of a client looking for advice on their product safety labeling strategy. Recently, it was advised by their insurance carrier, who was looking to provide products liability insurance to their company, to have Clarion Safety Systems review their current labeling for compliance. Something Clarion offers free to virtually everyone. This company was a manufacturer of conveyors, glass breakers, bag breakers, along with other material handling and sorting systems for the solid waste and recycling industries. They were using what I've termed in the past as the old "OSHA-style" formatting. There are several things wrong with that style of formatting. Some of the major ones are that they generally include very short messages that do not convey all the necessary elements a label should convey (hazard identification, consequence of interaction, how to avoid the hazard, and level of severity). Normally, you'll see something like "Danger: Keep Out". Keep out from what? What if I didn't, what would happen? Would I get zapped by electricity? Will the cops come and arrest me? You get my point...ANSI Z535.4 formatting allows for more explicit information, in a concise manner. The other problem with "OSHA-style" formatting is that it doesn't have a panel for the use of symbols. Symbols are, in my opinion, a necessity to have when conveying safety information. For one, they communicate across language barriers. This day and age there are all sorts of different ethnicities present even in US factories and manufacturing environments. Not all speak English. Symbols help in these instances. The other great thing about symbols is that they serve to quickly remind. If someone were to come in contact with a hazard, they need to respond immediately to avoid it. Not many people will stand there and read the entire label. Symbols help to speed the avoidance process up and get the person out of harms way...faster. There are other things wrong with "OSHA-style" formats, but we'll stop here for now.

Once we corrected the formatting issue, the client asked my opinion regarding translations. A huge topic right now when developing safety labels is when should I translate, or better yet, do I have to translate at all. The only thing ANSI Z535.4 has to say about translations is that they are an optional consideration and that if you choose to do so, they should be "checked regarding their appropriateness for the intended audience" (it should be noted that this standard is just a guideline, there's still a lot of grey areas. essentially it is up to the manufacturer to decide from the best options presented). ANSI also provides 29 translated signal words for you to use which is helpful. So back to the question, should I? do I? am I required to translate? What I can tell you is that the Machinery Directive 2006/42/EC says warnings should preferably use readily understood symbols and/or have one of the languages of the country in which the machinery is to be used accompanied, upon request, by the languages understood by the operators. So if  you're shipping into the EU, you probably should translate appropriately. This is a topic that will be debated for quite some time. Hopefully I can provide better clarification in future posts.

So what did the client decide? They standardized all their labeling in the US to a bi-lingual safety label format using English and Spanish/Mexican text. When shipping internationally, they will use a bi-linigual format as well, depending on what country. A sound strategy and much, much better than their previous one.

P.S. Did you know that you can use ISO-formatted symbols and be compliant with ANSI? These folks incorporated ISO symbols which made them fully compliant with both ANSI Z535.4 and ISO 3864-2. There is one format that meets both. More on that later...

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