Message from Geoffrey Peckham about Effective Safety Communication

This video speaks for itself. Very well done and communicates the importance of developing safety communication using best practice standards.

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...

Is ANSI Z535.4 a legal requirement?

Unfortunately, there isn't an easy "Yes" answer for this question. The ANSI Z535.4 standard is a voluntary standard, which means technically they are NOT a legal requirement. However, you could argue that they are mandatory. From a legal perspective, every product manufacturer has a legal "duty to warn" against the hazards that are associated with their product. You should be providing warnings to the installers, users, services, and disposers of your product - essentially anyone who could come in contact with it. Part of this legal requirement is to "meet or exceed" the current best practices. History tells us that the ANSI Z535 standards are viewed as the standards benchmark in "inadequate warnings" cases. State and federal courts have said that these standards represent the state of the art. So, while voluntary, they're really essential. Hopefully your legal council is advising the same.

I thought I was covered by following OSHA regulations on safety signs??

I've attended many trade shows in the material handling, packaging, semiconductor, and processing equipment industries. Although the percentages vary from show to show, what I continue to notice is that many manufacturer's still use the "OSHA-style" formatting for their product safety signs and labels. The only explanation I can come up with is that those manufacturer's are just simply not aware of the current requirements. In 1998, the ANSI Z535.4 standard notified manufacturers that the "OSHA-style" labels would be obsolete beginning the next published revision (2002). So, for almost 10 years now, these kinds of labels are no longer compliant with the ANSI Z535.4 standard. Companies are at HUGE risk for following this outdated formatting which I'll explain in a future post. What I did want to address here is the question "Will I still be in compliance with OSHA if I use ANSI Z535.4 formatted safety labels?". The answer is yes. The OSHA regulations for safety signs were written back in the 1970's and were based on the ANSI Z53 and Z35 standards. Those two standards were combined in the 1980's to form ANSI Z535. Complying with the latest version of the documents of which the original regulations were based WILL meet OSHA compliance. The legal term for this is "de minimis situation". OSHA does not update its regulations whenever a standard changes, and because of this, they do not want stop companies from using the latest in safety technology.  

What standards should I look to for product safety label development?

The primary standard to follow for products sold in the United States is ANSI Z535.4 for Product Safety Signs and Labels. This standard was first published in 1991, revises every several years, and is due for a revised publication in June of 2011. There are some manufacturer's who are not aware that this standard exists and therefore follow OSHA regulations that were put in place over 60 years ago. There are a great majority of manufacturer's who are unaware that the ANSI Z535 standard revises, most still following outdated versions and should look to update to the current version.

For international standards, the primary standard is ISO 3864-2. There are distinct differences between the two, however in 2007 ANSI Z535.4 harmonized with this standard, therefore allowing a label format that meets both standards. A point that many manufacturer's are unaware of.

There are several product specific standards that exist, however these two standards are the primary standards to look to when developing safety labels.