CETA in force!

CETA comes into force today, 21-Sep-2017

If you are unfa­mil­iar with CETA, the Com­pre­hen­sive Eco­nom­ic and Trade Agree­ment, this ground­break­ing trade agree­ment between Cana­da and the Euro­pean Union will be a game-chang­er for Cana­da. Until today, the actu­al date for imple­men­ta­tion of the agree­ment has been a mov­ing tar­get. There were at least two pre­vi­ous dates announced by the Cana­di­an gov­ern­ment, but each time the dates passed with­out the agree­ment com­ing into force due to issues that need­ed to be resolved.

So what does this mean for Cana­di­ans? As of today, 98% of Cana­di­an prod­ucts can now enter into the EU tar­iff-free. With­in two years, 99% of prod­ucts will be tar­iff-free. The agree­ment embod­ies much of what the EU sys­tem is based upon: Four pil­lars of free­dom are entrenched in the agree­ment.

The Four Pil­lars include the free­dom of move­ment of peo­ple, goods, ser­vices and cap­i­tal. This phi­los­o­phy has brought sig­nif­i­cant pros­per­i­ty and free­dom to Euro­pean cit­i­zens. With­in the“Schengen Area”, EU cit­i­zens can move freely across nation­al bor­ders with­out pass­ing through cus­toms, in a very sim­i­lar way to Cana­di­ans mov­ing from Province to Province. EU cit­i­zens can work in any Schen­gen coun­try with­out the need for work­ing visas or cit­i­zen­ship in the new coun­try they have cho­sen. Sim­i­lar free­doms exist for goods, ser­vices and mon­ey.

Under CETA, sim­i­lar free­doms are avail­able to Cana­di­ans, although with some restric­tions since CETA does not mean that Cana­da is now an EU Mem­ber State. Goods can flow from Cana­da to the EU, and from the EU to Cana­da with­out tar­iff restric­tions, except in some lim­it­ed cas­es. Busi­ness­es who want to set up oper­a­tions in the EU can do this with lim­it­ed restric­tions, and Cana­di­an pro­fes­sion­al work­ers can move to the EU to staff these new oper­a­tions with­out the need for restric­tive work visas. Invest­ment in EU oper­a­tions has gained pro­tec­tions through EU law so that these invest­ments are bet­ter pro­tect­ed. Cana­di­an ser­vice busi­ness­es can now pro­vide their ser­vice prod­ucts to EU cus­tomers with lit­tle restric­tion. Cana­di­an busi­ness now has free access to a mar­ket­place of 500 mil­lion new cus­tomers, near­ly 14 times larg­er than the Cana­di­an mar­ket. The EU mar­ket is worth near­ly €2.4 tril­lion in exports alone. This is an oppor­tu­ni­ty Cana­di­ans can’t afford to miss.

With the insta­bil­i­ty being cre­at­ed by the cur­rent US admin­is­tra­tion and the bul­ly tac­tics that are being used to force the rene­go­ti­a­tion of NAFTA, Cana­di­an busi­ness should take the oppor­tu­ni­ty pre­sent­ed to us today to turn our eyes to the EU, a union of coun­tries who are open and friend­ly to Cana­di­ans. Peo­ple who want to work with us, who want our prod­ucts and ser­vices. Many Cana­di­ans sup­port scrap­ping NAFTA if key pro­vi­sions can’t be met.

For more infor­ma­tion on CETA and what it will mean for Cana­di­ans, please see Doing Busi­ness in Europe — CETA: Cana­da and the Euro­pean Union Ush­er In a New Era of Trade.

21-Sep­tem­ber-2017 is a day to cel­e­brate. The future looks bright!

Machinery Safety Labels: 3 Top Tools for Effective Warnings

This entry is part 1 of 3 in the series Safe­ty Labels

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.


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


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)


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.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.

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

A Note about Our Travel Policy

Canadian passport

We believe trav­el gives us a broad per­spec­tive both per­son­al­ly and pro­fes­sion­al­ly. Our focus is glob­al. Our eth­i­cal posi­tion is clear; we believe in the health and safe­ty of ALL peo­ple. We believe in the pow­er of sci­en­tif­ic data, and in the pow­er of con­nect­ing with oth­ers glob­al­ly, so we might learn from one anoth­er.

Com­pli­ance inSight Con­sult­ing Inc. began 17 years ago; we spend our time work­ing to help ensure the safe­ty of peo­ple who work with machin­ery. We have clients whose busi­ness­es span the globe, but most are in North Amer­i­ca. And as many of our read­ers know, Doug has always been active with­in the glob­al reg­u­la­to­ry com­mu­ni­ty, rep­re­sent­ing both our indus­try and Cana­da. (Doug has occa­sion­al­ly found him­self on more air­craft in a month than many air crews!)

New Travel Policy

The cur­rent US admin­is­tra­tion has made trav­el to the US prob­lem­at­ic or even impos­si­ble for many. Our com­pa­ny and many of our col­leagues are among those affect­ed by these deci­sions, as the glob­al com­mu­ni­ty scram­bles to deal with what has become a dai­ly onslaught of shift­ing US pol­i­cy deci­sions. As a result, we have decid­ed to stop trav­el­ling to the US, effec­tive imme­di­ate­ly, and for the fore­see­able future.

Our Solution

Picture of a notebook computer with people participating in a web meeting

Our clients from the US are our friends and neigh­bours, and we are still here to help.

We will con­tin­ue to offer a vari­ety of web-based solu­tions to our clients, pro­vid­ing train­ing and con­sult­ing ser­vices via web meet­ing soft­ware, phone and email. We are cur­rent­ly inves­ti­gat­ing cloud-based edu­ca­tion solu­tions so we can offer a com­pre­hen­sive online train­ing por­tal. We will con­tin­ue to serve our US clients as we have in the past, we just won’t be stop­ping by for a vis­it for a while. We hope you under­stand.

Doug Nix
Man­ag­ing Direc­tor,
Prin­ci­pal Con­sul­tant
Kim­ber­ly Nix
Man­ag­ing Direc­tor

Image cred­its: cic.gc.ca, rhubcom.com

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Acknowl­edge­ments: images as cred­it­ed
Some Rights Reserved