Tough question to answer. I would recommend speaking to product liability specialists and/or attorneys on this matter. I have personally seen companies sued for inadequate warnings on equipment that was manufactured dating back to the 1960's. My understanding is that there is no standard or requirement out there to follow on this topic.
I do have an opinion on the matter of course. If you feel that the labels on equipment that are out in the field do NOT meet the elements deemed as "adequate", it is my feeling that you should do everything possible to help protect the users of your product. Retrofit with new labels. In doing so, this can also potentially limit the liability risk. There's obviously several factors to consider when undertaking a project like this. First, do you know where your product landed? If you're selling consumer products, it's virtually impossible to know where all the products you sold ended up. But, if you're manufacturing 1,000 machines a year direct to the customer, you probably have a good idea of which companies to contact. Something as a simple notification that new safety labels have been made available to those companies could be a good strategy. You could even make them available through service representatives. Whatever is reasonable.
Unfortunately, this is such a grey area that there isn't one defined solution. If you'd like to contact product liability attorneys or specialists, feel free to e-mail me. I will refer good ones.
I do have an opinion on the matter of course. If you feel that the labels on equipment that are out in the field do NOT meet the elements deemed as "adequate", it is my feeling that you should do everything possible to help protect the users of your product. Retrofit with new labels. In doing so, this can also potentially limit the liability risk. There's obviously several factors to consider when undertaking a project like this. First, do you know where your product landed? If you're selling consumer products, it's virtually impossible to know where all the products you sold ended up. But, if you're manufacturing 1,000 machines a year direct to the customer, you probably have a good idea of which companies to contact. Something as a simple notification that new safety labels have been made available to those companies could be a good strategy. You could even make them available through service representatives. Whatever is reasonable.
Unfortunately, this is such a grey area that there isn't one defined solution. If you'd like to contact product liability attorneys or specialists, feel free to e-mail me. I will refer good ones.
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