What are the standards I should look to concerning safety labels for products?

For American standards on equipment sold in the United States, the American National Standards Institute's Z535.4 Product Safety Label Standard, first published in 1991, revised in 1998 and again as of July 1, 2002.

For international standards, the primary general standard concerning safety signs is ISO 3864 which is under the responsibility of ISO/TC 145. This standard has been separated into two parts, Part 1 for Public Area and Facility Signs, and Part 2 for Product Safety Labels, a new standard to be published in November of 2004. The U.S. is instrumental in writing this new standard and Mr. Peckham, President of Clarion and Chair of the U.S. TAG to ISO/TC 145, is its primary author.

Though other product-specific ANSI, ISO and IEC standards exist (as well as several UL and NEMA standards), the principle standards to look to for developing the vast majority of product safety labels continue to be ANSI Z535.4 and the new ISO 3864-2 standard.

Where do I obtain the current version of the ANSI and ISO standards?

Global Engineering Documents is one of the easiest places to purchase standards, many in PDF format that can be downloaded upon payment. To reach them, call 800-854-7179 or visit Clarion's resource links page. Please remember that it is illegal to copy and distribute standards to others. This is important because without the funds that result from standards sales, organizations like ANSI, ISO and IEC would not be able to carry on their valuable work.

Is there a conflict between ISO and ANSI over which safety label format to choose?

Yes. It is important to note that a problem often arises when it comes to choosing safety labeling formats. First there is the need to meet international requirements for exported products - which means using international safety label formats. Second, there is the need to use U.S. standards because they are the measure U.S. courts use to determine the "state-of-the-art" (in this case, ANSI Z535.4). Although Z535.4 is a voluntary standard (meaning there is no law that states that you have to use it), your legal duty to warn in the U.S. is based on meeting or exceeding this standard. Therefore, in cases where ISO and ANSI Z535.4 standards apply, harmonization may be the best alternative.

What progress has been made towards safety label standards harmonization?

Clarion's President, Geoffrey Peckham, has been a member of the ANSI Z535 Committee since 1992 and, since 1996, Chair and Head of the Delegation for the U.S. Technical Advisory Group to the ISO committee responsible for the ISO 3864 - the primary international standard pertaining to safety labels, signs, colors and symbols. His overall goal in these positions has been to bring about a degree of harmonization between the U.S. and international product safety labeling standards so that manufacturers have the ability to choose appropriate safety label formats for the products they sell to both U.S. and international markets. The effort towards harmonization is ongoing with advances being made in every revision of the standards. At this point in time not every format meets both U.S. and ISO standards. Thus, it is necessary to understand more about the ANSI Z535.4 and ISO 3864 standards so you can make appropriate decisions regarding the overall choice of which formats to use for your product safety labels.

UPDATE: As of November 2004, the newly published ISO 3864-2 standard, Graphical Symbols - Safety Colours and Safety Signs - Part 2: Design Principles for Product Safety Labels, includes options that are very close in format to the ANSI Z535.4 formats. Likewise, the 2006 revision of the ANSI Z535.4 Product Safety Sign and Label Standard will most likely include a reference to this ISO standard in the normative body of standard. This step, in effect, will allow the use of ISO-formatted labels for products sold in the U.S.

Currently and with the publication of these standards, the Clarion "harmonized" format will most likely be the most popular option for those companies desiring consistency of safety labels for both the U.S. and international markets. For more information, see the On Formats FAQ.

Are the ANSI Z535 standards a legal requirement for American industry?

There are two parts to the answer to this question. First, all ANSI standards are voluntary. Thus, in short, the ANSI Z535 standards are voluntary standards - they are not a legal requirement. But in practice they are essentially mandatory. Here is the reason why: From a legal point of view, product manufacturers have a legal "duty to warn" about hazards associated with the use or maintenance of their products. Part of this legal requirement is the duty to "meet or exceed" standards. The ANSI Z535 standards are held up in U.S. courts as THE standards benchmark to "meet or exceed." Though the ANSI Z535 standards are voluntary, state and federal courts have said that these standards represent the "state-of-the-art." So from a product liability perspective, your legal counsel will usually advise you to comply with ANSI Z535 for all products sold for the U.S. market.

The second part of the answer is found below: Will I be in compliance with OSHA if I change my safety labels and signs to comply with the newly revised ANSI Z535-2002 standards?

Will I be in compliance with OSHA if I change my safety labels and signs to comply with the newly revised ANSI Z535-2002 standards?

Yes! The OSHA regulations for safety signs (1910.144) were written back in the 1970s and they were based on the Z53 and Z35 standards. These regulations are still law for workplace owners. The Z535 committee was formed when the Z53 and Z35 standards combined back in the 1980s. Now what is interesting is this: The newly revised 2002 ANSI Z535 standards have replaced the old "OSHA" formats with the ANSI Z53.4 format for all new safety labels, signs and tags used in the U.S. So the question now is, if you use the new formats will you be in compliance with OSHA? YES. Complying with the latest version of the documents on which the original regulations were based WILL meet OSHA compliance. The legal term for this is a "deminimus situation." OSHA does not update their documents whenever a standard changes and, since this is the case, OSHA does not want to stop companies from utilizing the latest in safety technology. So they acknowledge and even encourage companies to comply with the latest ANSI standards.

Why should I comply with the ANSI Z535 Standard?

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What is the relationship between product liability and state-of-the-art safety labels?

Meeting the current ANSI Z535.4 safety label requirements is an important part of designing the products your company sells in the United States. Even when appropriate design features and safety devices are incorporated into machinery, some residual risks may remain. Safety labels alert operators or other exposed people to these residual risks, instruct them on how to avoid the hazard, inform of the consequence of interaction with the hazard, and conveys the severity of the hazard. Also, since many accidents are the result of impulsive actions, a safety label can remind people of open and obvious hazards that might otherwise have caused them injury.

With the ever-increasing risk of litigation, the need for state-of-the-art safety labels has become virtually mandatory for equipment manufacturers. Using state-of-the-art safety labels becomes important when it is understood that lawsuits containing the allegation of a "Failure to Warn" or "Inadequate Warnings" are the predominate form of product liability litigation in the United States. The fact is, if a personal injury occurs during the use or service of equipment and it did not have a state-of-the-art safety label, there is a significant chance that the equipment manufacturer will be brought into a product liability lawsuit. Thus, use of the most current version of the ANSI Z535.4 standard for product safety labels is a necessity for all products using safety labels sold in the U.S..

What is "state-of-the-art"?

"State-of-the-art" is a term that has many definitions. However, in the area of safety labeling, it typically means that the safety labels were designed according to the requirements set forth by the most current standards, in this case, ANSI Z535.4.

Does the 2002 revision of the ANSI Z535.4 Standard incorporate ISO safety label formats?

Initially it was thought by the Z535 committee that the 2002 revision would include the ISO formats. But after careful consideration, the committee decided to wait. The 2002 revision of the ANSI Z535.4 standard includes an annex C that describes the use of ISO safety label formats but acknowledges that differences currently exist between ANSI Z535.4 and international standards and commits to including efforts towards harmonization in the next (2006) revision which will most likely reference the ISO 3864-2 standard in the normative body of the standard.

Why should I comply with ISO standards?

In contrast to the U.S. market, the multiplicity of languages in the international marketplace has created the demand for symbol-based safety labels. Concerning capital equipment used in the workplace, the European perspective also places a special emphasis on using equipment manuals and operator training to reinforce the comprehension of the safety labels shown on the equipment.

Meeting current international safety labeling requirements is an important part of preparing your product for export. ISO-formatted and harmonized safety labels are one of the most visible aspects of your product's design. If your products ship to Europe, proper safety labeling is essential to meet CE marking requirements. If the wrong safety labeling system is used, you risk your equipment failing inspection.

How can I stay informed about safety label standards?

Our commitment at Clarion is to keep our customers up-to-date with the most current information concerning safety labels - that is part of the service that makes Clarion Safety Systems unique in its field. We are committed to participating in the various safety label standard committees - this effort is on going and will continue to be an essential part of our business. This expertise is an essential part of the safety labels we sell and the design production services we offer our customers. To receive updates on issues pertinent to product safety labels, we recommend that you sign up for our resource information-driven email newsletter.

We look forward to using our production services to assist your company in the revision of your old non-compliant labels and the development of new safety labels in the years to come. If you have any questions, please do not hesitate to contact us.

Does a company need to retrofit old equipment in use out in the field with new safety labels?

With the 2002 revision of the ANSI Z535.4 standard making obsolete the old Z35 formatted safety labels, this question is being asked fairly often. It is best to consult your company's legal counsel on this issue to determine the answer that is right for your company. The following is the general advice we can offer on this subject:

The first factor to look at is whether the old safety labels adequately communicate the safety information necessary by today's standards. If they are inadequate, in the name of being a safety conscious company that does everything possible to protect its product users, you might determine that you have a problem and that something needs to be done about providing better safety labels to those who use your products.

If you determine that something does need to be done (your old safety labels are inadequate in their content), then you must make a determination based on what is reasonable. To arrive at this answer, you ask, "Does my company know where their products are?" For example, if you manufactured portable power drills, the kind you might buy at WalMart, there would be no way to trace ownership of your products. So the ability to retrofit is extremely difficult if not impossible. If, on the other hand, you manufactured 1000 process mixers in the past 30 years and you continue to sell repair parts to the users of these mixers, it would be entirely reasonable for you to send out a notice that new safety labels exist. You might even send such a letter by registered mail so that you could prove in any future court case that you had made an effort to notify all of your customers of the need to update the safety labels that appear on their equipment. You could also just send them the new safety labels free of charge. Or you could send your field service representative out to manually install new safety labels. Again, determining what is reasonable will be the key.

There are many side issues related to whether or not to retrofit, but the goals remain the same: protecting users from injuries and protecting your company from product liability lawsuits.