Machinery Safety Labels: 3 Top Tools for Effective Warnings

This entry is part 4 of 4 in the series Hierarchy of Controls

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 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:

  1. 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.
  2. 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: 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. 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 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 quite com­mon to see either ANSI Z535 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 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.

Safety label standard ANSI Z535.4 Product Safety Signs and Labels
The ANSI Z535.4 product safety label stand­ard
Safety label standard ISO 3864-2 Graphical symbols - Safety colours and safety signs - Part 2: Design principles for product safety labels.
The ISO 3864 – 2 product safety label stand­ard

TOOL #2: RISK ASSESSMENT

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. 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 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.

MIL-STD 882 risk assessment form
A typ­ic­al risk assess­ment scor­ing mat­rix (based on MIL STD 882 as defined in ANSI B11/​ISO 12100 Safety of Machinery – Risk Assessment Annex D)

TOOL #3: PICTOGRAPHIC  SAFETY LABELS FOR GLOBAL MARKETS

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 ANSI Z535.4 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.

Safety label by Clarion Safety Systems on a machine
A typ­ic­al Clarion machine safety label that uses an inter­na­tion­ally format­ted graph­ic­al sym­bol and a format that meets both ANSI Z535.4 and ISO 3864 – 2 design prin­ciples (Design ©Clarion Safety Systems. All rights reserved.)

Concluding Thoughts

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​.clari​on​safety​.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.

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Acknowledgements: Derek Eversdyke, Clarion Safety Systems, LLC
Some Rights Reserved

CSA Z432 Third Edition Open for Public Review!

CSA Z432, Safeguarding of Machinery, is the basic stand­ard for Canada when it comes to most types of machinery. Only Power Presses and Press Brakes, and Industrial Robots are covered sep­ar­ately in their own stand­ards. CSA Z432 provides guid­ance on import­ant top­ics, like:

  • Risk Assessment
  • Risk reduc­tion through the Hierarchy of Controls
  • Guard design require­ments
  • Safeguarding device applic­a­tion require­ments, and
  • Instructions and inform­a­tion for use

This stand­ard should be used by every­one in Canada respons­ible for the safe design of machinery used in Canadian work­places, and for the safety of work­ers who use machinery in their daily tasks.

CSA has just opened pub­lic review on CSA Z432, Safeguarding of Machinery, third edi­tion. If you are a user, a build­er of machinery, or an eval­u­at­or of machinery, this is your oppor­tun­ity to see the draft of this import­ant stand­ard, and to make com­ments to help the Technical Committee improve the stand­ard on your behalf.

To access the pub­lic review copy, you must register on CSA’s Public Review sys­tem. Registration is free and allows you to get read-​only access to the drafts of all new stand­ards that CSA is pre­par­ing to pub­lish. The time you take to read and com­ment on new stand­ards is very valu­able to the Technical Committees, as it helps us to cor­rect areas where mis­un­der­stand­ings or con­fu­sion may exist, and to add mater­i­al where it is needed.

See the Draft

Review closes 2-​Jan-​2016, so don’t delay!

If you need more inform­a­tion, please con­tact Jill Collins at CSA Group.

 

Translation Bafflement

iStock_000009386795Small - Photo of Instruction manualI’ve been noti­cing a trend with some of my cli­ents that I am hav­ing a really hard time under­stand­ing – maybe a read­er can help me get this…

A basic require­ment in the EU is that manu­als and oth­er inform­a­tion a man­u­fac­turer provides to their cus­tom­er be provided in the offi­cial lan­guage of the coun­try where the product is being sold. One pos­sible way around this is to provide a graph­ic­al set of instruc­tions. Probably the best example of this is IKEA, where everything is done graph­ic­ally.

To me, this is only logic­al, after all, if I buy a product I’d like to be able to read the instruc­tions in English, and I can’t ima­gine that oth­er people wouldn’t want to read the instruc­tions in their nat­ive lan­guage too.

But here’s the thing — I reg­u­larly have cli­ents who don’t want to trans­late their instruc­tion manu­als. They look for every pos­sible excuse, from ‘those guys didn’t do it’, refer­ring to a com­pet­it­or, to ‘the cus­tom­er speaks and reads English, so we don’t need to trans­late’. The first excuse is laugh­able in my opin­ion, and the last one is at least some­what plaus­ible, but the law requires trans­la­tion. Simple. Sell the product in Germany, provide instruc­tions in German. Sell it in Italy, provide instruc­tions in Italian.

IKEA Desk Chair Instructions
Graphical Instructions, IKEA Style

This even holds true here in Canada where I live. In most of Canada, English is pre­dom­in­ant, but every pack­age is marked in English and French, and instruc­tions are provided in English and French. Why? Because we have two offi­cial lan­guages, English and French.

So what’s the big deal? I under­stand that there is a cost attached to trans­la­tion, but it’s a cost of doing busi­ness in anoth­er mar­ket and should have been eas­ily fore­see­able in devel­op­ing the product budget.

If you can explain this to me, I’d love to hear from you!