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.

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.

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.

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.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.

Copy­right secured by Digi­prove © 2017

Acknow­ledge­ments: Derek Evers­dyke, Clari­on Safety Sys­tems, LLC

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