Machinery Safety Labels
The third level of the “Hierarchy of Controls” is “Information for Use.” Safety Labels are a key part of the Information for Use provided by machine builders and are often the only information many users get to see. This makes the design and placement of the safety labels critical to their effectiveness. There is as much risk in the under-use of safety labels as in the over-use of safety labels. Often, machine builders and users simply select generic labels easily available from catalogues, missing the opportunity to design labels specific to the machine and the hazards present.
Product Safety and Liability Limitations
If your company manufactures machinery that has potential hazards associated with its transportation, installation, use, maintenance, decommissioning and/or disposal, you likely have a very strong need to create effective product safety labels. This task must be done right: product safety labels play an integral role in your company’s product safety and liability prevention efforts. And that means that people’s lives and your company’s financial well-being are on the line. On that note, it’s important to keep in mind these two factors when it comes to effective safety labels:
- If properly designed, they can dramatically reduce accidents. This improves a product’s overall safety record but adds to a company’s bottom line by reducing product liability litigation and insurance costs.
- If poorly designed, needed safety communication does not occur, which can lead to accidents that cause injuries. With these accidents, companies face high costs in settling or fighting lawsuits because their products lacked “adequate warnings.”
With the rise in product liability litigation based on “failure to warn” over the past several decades, product safety labels have become a focal point in lawsuits faced by capital equipment manufacturers. Let’s look at three best-practice tools for product safety label design. These tools can provide insight to help you create or improve your safety label strategy to better protect your product users from harm and your company from litigation-related losses.
TOOL #1: SAFETY LABEL STANDARDS
As a manufacturer, you know that your legal obligation is to meet or exceed the most recent versions of standards related to your product at the time it’s sold into the marketplace. When defining your product safety labels, warning label standards are the first place to turn. Until 1991, there was no overarching, multi-industry standard in the U.S. or the rest of the world that gave definitive guidance on the proper formatting and content for on-product warnings. In the U.S., that changed nationally with the publication of the ANSI Z535.4 Standard for Product Safety Signs and Labels in 1991 and internationally with the publication of ISO 3864-2 Design Principles for Product Safety Labels in 2004.
As of 2017, Canada does not have a warning label standard. Since Canada imports machinery from the U.S. and the EU, it is common to see either ANSI Z535 style labels or ISO 3864 style labels on products. Under Canadian law, either type can be used. However, Québec has specific requirements for French-language translations, and many CSA standards prescribe specific hazard warning labels that do not conform to either ANSI or ISO styles. If you are marketing your product in Canada, check the relevant electrical safety standard(s) for your product, ensuring that the product’s markings conform to those standards’ requirements.
Following the design principles in ANSI Z535.4 or ISO 3864-2 will give you a starting place for both the content and format choices you have to make for your products’ safety labels, bearing in mind the language requirements of your jurisdiction. Note that both of these standards are revised regularly, every five years or so, and it’s important to be aware of the nuances that would make one format more appropriate for your product than another.
TOOL #2: RISK ASSESSMENT
From an engineering perspective, your job is to identify potential hazards and determine if they need to be removed through design, guarded, or warned about. From a legal perspective, your job is to define what hazards are “reasonably foreseeable” and “reasonable”? ways to mitigate risks associated with hazards that cannot be designed out. This is where risk assessment comes into play.
In today’s world, a product is expected to be designed with safety in mind. The risk assessment process helps you to accomplish this task. At its most basic level, risk assessment involves considering the probability and severity of outcomes that can result from potentially hazardous situations. After identifying the potential hazards from your product at every point in its lifecycle, you then consider various strategies to eliminate or reduce the risk of people interacting with these hazards.
The best practice risk assessment standards today (i.e., ANSI Z10, ANSI B11, CSA Z432, CSA Z1002, ISO 12100, ISO 31000, ISO 31010) give you a process to use to quantify and reduce risks. Using these standards as the basis for a formalized risk assessment process will not only help you to develop better safety labels and a safer product, but it will also provide you with documentation that will help you to show the world that you are a safety-conscious company who uses the latest standards-based technology to reduce risks. This will be very important if you are involved in product liability litigation.
There are many risk-scoring tools available to engineers. ISO/TR 14121-2 offers both a risk matrix and a decision tree that can be used, while ANSI B11.0 uses a matrix approach. Other standards have similar, slightly different tools, but they all have the same goals.
Tools that are not suitable for scoring risk to people include FMEA and its variants and similar tools that are designed to assess the probability of specific faults occurring. These tools play important roles in functional safety and reliability-and-maintainability analysis but not a risk assessment.
TOOL #3: PICTOGRAPHIC SAFETY LABELS FOR GLOBAL MARKETS
A large number of machinery manufacturers sell their products around the globe; when this is the case, compliance with global standards is required. The ANSI Z535.4 and ISO 3864-2 product safety label standards and the EU machinery directive place emphasis on using well-designed symbols on machinery safety labels so information can be conveyed across language barriers.
The EU Machinery Directive 2006/42/EC requires that all information for use be provided in the official languages of the country of use. Information for use includes hazard warning signs and labels that bear messages in text. Adding symbols also increases your label’s noticeability. Using symbols to convey safety is becoming commonplace worldwide and not taking advantage of this new visual language risks making your product’s safety labels obsolete and non-compliant with local, regional and international codes. In ISO 3864-2’s latest 2016 update, a major change in ISO label formats was made: a new “wordless” format that conveys risk severity was added to the standard. This new label format uses what ISO calls a “hazard severity panel” but no signal word. It communicates the level of risk through colour-coding of the hazard severity panel. This format option eliminates words, eliminating translations.
It should be noted that sometimes symbols alone cannot convey complex safety messages. In these cases, text messages are often still used. When shipping to non-English speaking countries, the trend today is to translate the text into the language of the country in which the machine is sold. Digital print technology makes this solution much more cost-effective and efficient than in the past.
The safety labels on your products are one of its most visible components. If they do not meet current standards, are not designed as the result of a risk assessment, and do not incorporate well-designed graphical symbols, your company risks litigation and non-conformance with market requirements. Most importantly, you may be putting those who interact with your machinery at risk of harm. Making sure your product safety labels are up-to-date is an important task for every engineer responsible for a machine’s design.
For more information on effective product safety labelling and resources you can use today, visit www.clarionsafety.com. Clarion also offers complimentary safety label assessments, using our experience with the latest standards and best practices to assess your labels and ensure that they are up-to-date in meeting today’s requirements.
Ed. note: Additional Canadian material contributed by Doug Nix.
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