Articles in this category discuss specific aspects of Information for Use. This is the Third Level in the Hierarchy of Controls, following Elimination/Substitution and Engineering Controls.
Identify the likely degree of injury that could occur
Instruct the reader about ways to avoid injury
Designing warnings seems a simple task. However, users may not be English speaking or literate. Depending on the jurisdictions where your product will be marketed, like the EU, text may not be desirable, so pictographic labels may be the most appropriate choice.
Complex Content
The content for your product safety label becomes complex when there are several elements involved in explaining what the hazard is and how to avoid it. But, with the latest update to ISO 3864–2 came a significant modification to the standard that provides a solution to consider in these situations: the new “wordless” format that conveys risk severity.
The wordless label format uses what ISO calls a “hazard severity panel” but no signal word. In place of words, the level of risk is communicated through colour-coding of the hazard severity panel. ISO-formatted symbols as well as what ISO calls “supplementary safety symbols” – symbols without an ISO-colored surround shape – can be used.
Example: Grill Industry Safety Label
As an example, let’s look at a label design created here at Clarion as part of Clarion’s work with ISO/TC 145.
When the barbeque grill industry needed a safety symbol that would warn people not to use grills in enclosed spaces, Clarion volunteered its design department’s skills to develop a new label design. The new label uses the ISO 3864–2:2016 wordless format.
The new safety label design includes a hazard severity level panel at the top. Below the severity label panel are five symbols: a safety symbol that defines the nature of the hazard, and four “supplementary” safety symbols. The supplementary symbols give instructions about “misuses” and “proper use” to help keep people safe. Much like the graphical instructions used in aircraft emergency instructions, the barbeque grill product safety label uses multiple graphics in a progressively illustrated design to communicate a complex message.
Learn More
There are multiple format options allowed by the ANSI and ISO standards, and it’s important to understand your choices – like this wordless option – so you can make the best decisions for your products or market. To learn more about how the wordless format can help solve complex messaging challenges, you can read Clarion’s recent article on this blog and the feature article in the October 2017 issue of InCompliance Magazine.
Get Help
Unsure where to start? Clarion is available to help. For more information on effective product safety labeling and resources that you can put to use today, visit www.clarionsafety.com. Clarion also offers complimentary safety label assessments, where we use our experience with the latest standards and best practices to assess your labels and ensure that they’re up-to-date in meeting today’s requirements.
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The Importance of Best Practice Product Safety Label Standards
Product safety labels serve an important role. They protect both users and manufacturers. Manufacturers are concerned with building products and protecting themselves from liability lawsuits. Users are concerned abut buying safe products. Manufacturers are also concerned with meeting the legal requirements for product labelling in the markets they serve.
As a product manufacturer, your legal obligation is to meet or exceed the current versions of standards related to your products. Regulatory compliance often hinges on meeting current standards. Many jurisdictions use compliance with the latest standards to gauge manufacturer’s efforts to meet best practices and legal requirements.
While keeping your product safety label designs up-to-date is not always a simple task, using the principal product safety label standards for the design and layout of your labels is key to fulfilling this requirement. If you are unsure about your product safety label designs, Clarion’s Safety Label Assessment Service can help get you on track.
Principal Product Safety Label Standards
In the U.S., the standard to look to is the ANSIZ535.4 Standard for Product Safety Signs and Labels [1]. Internationally, the primary standard for reference is ISO 3864–2 Graphical symbols – Safety colours and safety signs – Part 2: Design principles for product safety labels [2]. As Canada does not have a product safety label standard, following the design principles in ANSIZ535.4 or ISO 3864–2 will give you a starting point for both content and format choices for your product safety labels (bearing in mind any language requirements for your jurisdiction.)
Recent ANSI and ISO Standards Changes
The ANSIZ535.4 and ISO 3864–2 product safety label standards are revised according to ANSI and ISO procedures, typically every five years. ANSIZ535.4 is in the process of being balloted for reaffirmation without changes. If that occurs, the new version will be identical to the 2011 standard.
ISO 3864–2 was updated in December 2016. The revision included significant modifications to its content, including several changes to the label formats it allows. It is important to be aware of these changes and to understand why one label format may be more appropriate for your product than another.
Focusing in on ISO 3864–2:2016
In the latest version of the ISO 3864–2 product safety label standard, there are two major changes to ISO label formats:
The product safety label format that used a single safety symbol without an ISO-colored surround shape was removed from the standard. From the ISO 3864–2 standard’s perspective, and as defined in the standard’s first edition, product safety labels must use at least one ISO-formatted safety symbol (meaning, the symbol is placed in an ISO 3864-colored surround shape) in addition to the “general warning sign” that serves as the safety alert symbol on the label’s severity level panel. Non-ISO-formatted symbols can still be used on product safety labels, but only in addition to one or more ISO-formatted symbols. ISO 3864–2 defines these safety symbols as “supplementary.”
A new “wordless” format that conveys risk severity was added to the standard. This new product safety label format uses what ISO 3864–2 defines as a “hazard severity panel” without a signal word. The panel appearing at the top of the label communicates the level of risk through color-coding and the use of the ISO-formatted general warning symbol. This format option, already in use by a wide variety of product manufacturers, eliminates words – making translations unnecessary.
It is important to be aware that the changes made in ISO 3864–2 are significant. The changes open up new format possibilities that can help companies to better warn their users about hazards associated with their products. These changes make it a good time to reevaluate your labels.
Check to see if
they continue to meet your market’s requirements, and
whether the “wordless” format makes sense for your labelling.
The ISO product safety label standard gives you new options for conveying your safety message. The standard’s revision is an opportunity to fully refresh your labels, reviewing both their content and format in line with your product’s risk assessment and market requirements.
For more information on effective product safety labelling and resources that you can put to use today, visit www.clarionsafety.com. Clarion also offers complimentary safety label assessments, where we use our experience with the latest standards and best practices to assess your labels and ensure that they’re up-to-date in meeting today’s requirements.
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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 to users and are often the only information that 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 there is in the over-use of safety labels. Often, machine builders and users simply select generic labels that are easily available from catalogues, missing the opportunity to design labels that are specific to the machine and the hazards present.
Product Safety and Liability Limitation
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 not only 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 take place and this can lead to accidents that cause injuries. With these accidents, companies face high costs 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 leading 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 in order to better protect your product users from harm and your company from litigation-related losses.
TOOL #1: SAFETYLABELSTANDARDS
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. Warning label standards are the first place to turn to when it comes to defining your product safety labels. Up until 1991, there was no overarching, multi-industry standard in the U.S., or in the rest of the world, which 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 ANSIZ535.4 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 quite common to see either ANSIZ535 style labels or ISO 3864 style labels on products. Under Canadian law, neither is more correct. 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.
Following the design principles in ANSIZ535.4 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.
The ANSIZ535.4 product safety label standardThe ISO 3864–2 product safety label standard
TOOL #2: RISKASSESSMENT
From an engineering perspective, your job is to identify potential hazards and then determine if they need to be designed out, 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 related to your product at every point in its lifecycle, you then consider various strategies to either eliminate or reduce the risk of people interacting with these hazards.
The best practice risk assessment standards that exist today (i.e. ANSIZ10, ANSIB11, CSAZ432, CSAZ1002, 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 highly important should you be involved in product liability litigation down the road.
From an engineering perspective, your job is to identify potential hazards and then determine if they need to be designed out, 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.
A typical risk assessment scoring matrix (based on MILSTD 882 as defined in ANSIB11/ISO 12100 Safety of Machinery – Risk Assessment Annex D)
TOOL #3: PICTOGRAPHICSAFETYLABELSFORGLOBALMARKETS
A large number of machinery manufacturers sell their products around the globe and when this is the case, compliance with global standards is a requirement. The ANSIZ535.4 and ISO 3864–2 product safety label standards, and the EU machinery directive place an 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 labels’ noticeability. The use of 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 – making translations unnecessary.
It should be noted that sometimes symbols alone cannot convey complex safety messages. In these cases, text is 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 that appear on your products are one of its most visible components. If they don’t meet current standards, if they aren’t designed as the result of a risk assessment, and if they don’t 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 that you can put to use today, visit www.clarionsafety.com. Clarion also offers complimentary safety label assessments, where we use our experience with the latest standards and best practices to assess your labels and ensure that they’re up-to-date in meeting today’s requirements.
Ed. note: Additional Canadian material contributed by Doug Nix.
Original content here is published under these license terms:
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License Type:
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You may copy this content, create derivative work from it, and re-publish it for non-commercial purposes, provided you include an overt attribution to the author(s) and the re-publication must itself be under the terms of this license or similar.
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