Standards FAQ

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

For American standards on equipment sold in the United States, the primary safety label standard is the American National Standards Institute's (ANSI) Z535.4 Standard for Product Safety Signs and Labels. This standard was first published in 1991, revised in 1998, again in 2002, and once again in 2007. For products manufactured for sale in the United States, the 2008 version of this standard should be the one that is followed by product manufacturers.

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 several parts. Part 1 is for safety signs and Part 2 is for product safety labels. Part 2 was first published in 2004 and reaffirmed without changes in 2010. The U.S. was instrumental in writing part 2 of ISO 3864 and Geoffrey Peckham, President of Clarion and Chair of the U.S. TAG to ISO/TC 145, was 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 ISO 3864-2.

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 and no. 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 ANSI 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, such as when your market for your product is global in scope, using a harmonize approach to your product safety labeling is in your company's best interest. There are many choices to be made here and Clarion's customer service staff is well versed in assisting our clients through the options so right decisions can be made.

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, chair of the ANSI Z535.1 Standards for Safety Colors from 1994-2008, and chair of the ANSI Z535.2 Standard for Environmental and Facility Safety Signs since 2008. Likewise, Mr. Peckham has chaired and headed the delegation for ANSI to the international (ISO) standards in this field since 1996. As Chair and Head of the Delegation for the U.S. Technical Advisory Group to the ISO/TC 145 committee responsible for standards related to safety labels, signs, colors and symbols, Clarion has played a pivotal role in writing and revising the principle standards for both the U.S. and global standards in our respective field.

The overall goal of our involvement in the standards has been to bring about a degree of harmonization between the U.S. and international safety marking standards. Such progress allows manufacturers to have the ability to choose appropriate safety label formats for the products they sell to both U.S. and international markets. It also allows a global means of visually communicating safety to take place – for facilities, for public spaces, and for products. 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 safety signs, labels and markings. 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, the ANSI Z535 standards are voluntary standards – they are not a legal requirement. But in practice they are essentially mandatory. Here's the reason why: From a legal point of view, product manufacturers have a "duty to warn" about hazards associated with the transport, installation, use, maintenance and decommissioning/disposal 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" when it comes to warnings. 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 liability perspective, your legal counsel should be advising you to comply with ANSI Z535 for the safety labels for all products sold for the U.S. market and for all safety signs intended for U.S. facilities.

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 Z535-2007 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 revised 2007 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. The "deminimus" clause allows companies to comply with the latest ANSI safety sign 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 requirements contained in the current ANSI Z535.4 safety label standard is an important part of designing the products your company sells in the United States. Clarion fully understands these standards because we helped to write them. With the experience of working with over 10,000 clients in over 180 industries, we have the knowledge and the practical implantation experience necessary to help guide you through compliance in this area.

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 United States.

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

"State-of-the-art" is a term that has many definitions. However, in the area of safety markings, it typically means that the safety signs and labels were designed according to the requirements set forth by the most current standards. For the U.S., this means ANSI Z535. For the world, it means ISO 3864.

Does the 2007 revision of the ANSI Z535.4 Standard incorporate ISO safety label formats?

The answer, finally, is "yes." After nearly 15 years of standards harmonization work, the president of Clarion, Geoffrey Peckham, submitted change proposals that were accepted by the ANSI Z535 committee for inclusion in the ANSI Z535.4 product safety label standard. Essentially, an exception was made in section 3 that allows the alternative to use the ISO 3864-2 standard's formats if one desires to do so. This acceptance of the ISO standard for product safety labels by "incorporation by reference" is an excellent way to harmonize standards because it allows for continued compliance when the referenced standard is subsequently revised.

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. Again, Clarion's customer service staff is fully trained to assist you with understanding the formatting options before you when international compliance is required.

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 products we sell and the design and production services we offer our customers. To receive updates on issues pertinent to safety signs and labels, we recommend that you sign up for our information-driven email newsletter.

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

Do product manufacturers need to retrofit existing products out in the field with new safety labels and do facility owners need to change their facility safety signs to be up-to-date with today's standards?

With the ANSI Z535 standards making the old ANSI Z35 formatted safety signs and labels obsolete, this question is often asked. Our advice on these topics is as follows:

The first factor to look at is whether your old safety signs and labels adequately communicate the safety information defined by today's standards (for more information on the proper content of a safety sign or label, click here). If your safety signage is inadequate, in the interest of being a safety conscious and litigation-conscious company that does everything possible to protect its workers and/or its product users, you may see that you have a problem that needs to be fixed.

From a product manufacturer's perspective, there are many issues related to whether or not to retrofit. But the goal remains the same: to protect users from injuries and to protect your company from product liability lawsuits. You must make a determination based on what is reasonable. For instance, you should ask, "Does my company know where its products are?" Let's say you manufacture portable power drills, the kind you can buy at any department store. 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 and are available free of charge or for purchase. 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. Or you could send your field service representative out to manually install new safety labels. Again, determining what is reasonable will be the key.

From a facility owner's perspective, effectively informing employees, subcontractors and visitors of safety-related issues in and around your facility is imperative to keeping people safe from harm and reducing your liability exposure. At Clarion, we fully understand the components that go into a complete and unified visual safety communication system. Our systems include safe job practice signs, safety equipment location signs, accident prevention signs, company policy signs, security/limited access signs, process control and identification markings, and egress path markings. All of these components play an essential role in your company's effort to keep people safe. Our systems are the state-of-the-art, no other company has a better grasp of the knowledge and experience needed to effectively implement these systems. We look forward to helping you to adopt the latest in best practices in this field so that your company can achieve the goal of reducing risk and protecting people.