Geoffrey Peckham chairs both the ANSI Z535 Committee for Safety Signs and Colors and the U.S. Technical Advisory Group to ISO Technical Committee 145—Graphical Symbols. He is also a member of the U.S. Technical Advisory Group to ISO Project Committee 283—Occupational Health and Safety Management Systems. Peckham’s background includes more than two decades of experience in actively advancing safety communication. You can contact him at [email protected]
If your company manufactures machinery that has potential hazards associated with its transportation, installation, use, maintenance, decommissioning and/or disposal, you most likely have a very strong need to create effective product safety labels. This task must be done right. Simply put, the stakes are too high for this job to be done incorrectly. People’s lives and your company’s financial well-being are on the line.
From a vantage point of playing a role on standards committees in this field over the past 25 years, I’ve seen how safety labels can help or hinder those activities. While I’m not speaking for the standards committees on which I serve, I’ve noted first-hand two important outcomes:
1. If properly designed, safety labels can reduce accidents dramatically. 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, then needed safety communication does not take place, and this can lead to accidents that cause injuries. When such accidents happen, companies spend hundreds of thousands (if not millions) of dollars 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.
Also Read: Machine Safety
In this article, I’ll share what I believe are some key best practices and “tools” that shape the current state-of-the-art for product safety label design. My goal is to give the machine design engineer, risk manager or in-house legal counsel some insight that will help formulate an improved safety label strategy that will better protect its products' users from harm and its company from litigation-related losses.
Tool #1: The 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 is sold into the marketplace. Warning label standards are the first place you must turn when you define your product safety labels. Until 1991, there was no overarching, multi-industry standard in the U.S. (or in the world, for that matter) that gave definitive guidance on the proper formatting and content for on-product warnings. 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. Following the design principles in these standards will give you a starting place for both the content and format choices you have to make for your products’ safety labels. Note that both of these standards are revised 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. Here is where risk assessment comes into play.
