Standards FAQ
What product safety label standards should I be using?
For products sold in the United States, the primary safety label standard manufacturers should comply with is the
American National Standards Institute (ANSI) Z535.4 Standard for Product Safety Signs and Labels.
This standard was first published in 1991, revised in 1998, 2002, 2007, with the latest revision published in September 2011.
The ANSI Z535.4 standard is one of six standards in the ANSI Z535 series and all of these documents are on a five year revision schedule.
Thus, until 2016 when the ANSI Z535.4 standard will be republished, the safety signs and labels that manufacturers place on their products sold in the U.S. should be in full compliance with the 2011 version of this standard.
For products that are sold outside the United States, the primary international standard for product safety labels is ISO 3864-2, Graphical symbols — Safety colours and safety signs —
Part 2: Design principles for product safety labels, a standard written by the International Organization for Standardization (ISO) technical committee 145 (ISO/TC 145).
ISO 3864-2 was first published in 2004 and reaffirmed without changes in 2010. The U.S. was instrumental in writing the ISO 3864-2 standard and Geoffrey Peckham, President of Clarion and
Chair of the U.S. TAG to ISO/TC 145, was its primary author while it was in draft form.
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?
Visit Clarion's Resource Links web page to locate a source for the latest standards.
Please remember that it is illegal to copy and distribute standards to others. This is important because without the
funds that result from the sale of standards, organizations like ANSI, ISO, IEC and NFPA would not be able to carry on their
valuable work.
Should I take into account both the ISO and ANSI standards when I’m choosing a format for my product safety labels?
Yes, especially if you sell your products both abroad and in the United States. First, there is the need to meet international
requirements for exported products - which means using internationally acceptable safety label formats. Second, in the U.S. there
are American standards that must be met because they are the measure U.S. courts will use to determine "state-of-the-art”. If a
products liability lawsuit is brought against your company in the United States with the allegation of “failure to warn” or
“inadequate warnings,” your legal duty to warn will most likely be based on meeting or exceeding the ANSI Z535.4 standard.
Therefore, in cases where both ISO and ANSI standards apply, such as when you have both global and U.S. markets for your product,
using one of the formats that is acceptable by both ISO and ANSI will be in your company's best interest. There are several critical
choices that must be made here, and made right. One safety label format may be correct for one sector of your market and another
format the better choice for a different sector. Clarion’s Compliance Specialists can assist you in your efforts regarding this critical
safety and market-related issue. Feel free to give us a call.
What is Clarion’s involvement in safety sign standards?
On the U.S. front, Clarion's President, Geoffrey Peckham, has been a member of the ANSI Z535 Committee since 1992, chair of the
ANSI Z535.1 Standard for Safety Colors from 1994-2008, and chair of the
ANSI Z535.2 Standard for Environmental and Facility Safety Signs from 2008-2011. In 2011 he was confirmed
as the new chairman of the entire ANSI Z535 Committee.
On the international front, since 1996 Mr. Peckham has been chair and head of the delegation for the U.S. Technical Advisory Group
(TAG) to the international ISO technical committee responsible for standards related to safety labels, signs, colors and symbols
(ISO/TC 145). With this level of on-going standards leadership, you can fully appreciate our commitment to giving our customers the
highest level of expertise in this field.
Has progress been made in “harmonizing” ANSI and ISO safety label standards?
When our work began in 1995, things were in disarray. The U.S. did one thing, the rest of the world did something else (or nothing)
and never the two shall meet, as they say. Well, “never” was not going to work because safety communication and risk reduction had
to adapt as markets were becoming global and expectations for safety were becoming the norm worldwide. The goal was to bring
about a high level of “harmonization” between the ANSI and ISO safety labeling standards so product manufacturers around the
world could have the ability to choose appropriate safety label formats that could conform to both U.S. and international
standards.
With the latest publication of the ANSI and ISO safety labeling standards, the goal of product safety label standards harmonization
has been accomplished. This is great news! But now there’s a different consideration – which format should you choose? The most
recent versions of the principle ANSI and ISO safety labeling standards now accept several formats that are common to both. Your
objective now is to choose the right format(s) for your various markets.
To answer this question you must know who’s your audience, what’s their level of training, will text be necessary to communicate
the required message (and if so, are translations necessary for certain countries), which formats are preferred by various compliance
agencies, whether symbols can be used and if so, which ones? These are all questions that need to be answered and Clarion’s
Compliance Specialists are here to help you through the process.
Is using the ANSI Z535.4 Standard for Product Safety Labels a legal requirement for product manufacturers selling their products in the United States?
The labels that go on your products are one of the most visible means of knowing whether or not your engineers got things right
with regards to compliance to the various rules and regulations that pertain to your markets.
There are two important things to understand here . . .
First, compliance with nearly all ANSI standards is voluntary, including the ANSI Z535.4 product safety label standard. There is no law
that says you must use it (except occasionally when the U.S. Consumer Products Safety Commission specifies a specific warning for a
specific type of product).
Second, for all practical purposes compliance with the ANSI Z535.4 standard is essentially mandatory for products sold in the United
States that have hazards that need to be warned about. Here's why: From a legal point of view in the U.S., product manufacturers
have a "duty to warn" about hazards associated with their products that could occur over the product’s life. This includes the
product’s transport, installation, use, maintenance, decommissioning, and disposal. Part of this legal requirement is the duty to
"meet or exceed" applicable standards that are in place at the time your product is manufactured and placed in the market. Over
the past 20 years of case law, State and federal courts have repeatedly used the ANSI Z535.4 standard as the benchmark to judge
adequacy of warnings. In effect, this standard represents the "state-of-the-art."
So from a liability perspective, your legal counsel will most likely tell you to comply with latest version of the ANSI Z535.4 standard
for the safety labels that appear on all of your products sold in the U.S. market.
Will I be in compliance with OSHA if I change my workplace safety signs to comply with the newly revised ANSI Z535.2-2011 Standard for Environmental and Facility Safety Signs?
Yes! But to understand the answer, you’ll need to know a bit of history about the standards on this subject – because the standards
are the key that unlocks this puzzle in a couple of different ways.
The OSHA regulations for safety signs (1910.144) were written back when OSHA was first formed in the early 1970s. These original
regulations for signs have not been updated since then and yet they still set the requirement for workplace owners with regards to
identifying hazards and precautions in their workplaces. When these regulations were written by OSHA, they were based on the U.S.
standards in effect at that time, namely, the 1967 USASI Z53 Safety Color Code for Marking Physical Hazards and the 1968
USASI Z35 Standard Specifications for Accident Prevention Signs. Don’t be confused by the organizational titles here – the USASI
was the United States of America Standards Institute and it was renamed in 1969 to be the American National Standards Institute
(“ANSI” for short).
The ANSI Z535 committee was then formed when the Z53 and Z35 committees combined back in the 1980s. Therefore, the
ANSI Z535 standards are direct descendants of the Z53 and Z35 standards. This is an important fact, as you will see.
Now jump ahead to 1998. The ANSI Z535 committee had the goal of creating a single national uniform system for hazard recognition
that is thoroughly grounded in human factors studies and court precedents. The committee further recognized that the ANSI Z535.4
product safety label format should be the same format for safety signs on the walls. To further
this aim, they set a 5-year process in place whereby the ANSI Z535.4 format
(soon to become Z535.2) was made the “preferred” format for environmental and
facility safety signs, while the old Z35.1 format was made the “alternate” format. A footnote in the 1998 standard says that it is the
intention of the ANSI Z535 committee to remove the older “alternate” format from the standard in its next revision. And that is
exactly what happened. In 2002 the next revision of the ANSI Z535.2 Environmental and Facility Sign Standard removed the old
Z35.1 OSHA-accepted formats. An annex was added that explained that the old formats were now obsolete and all new safety
signage should use the new format (i.e. the ANSI Z535.4 style of sign format).
At Clarion we fully recognize that the direction of the ANSI Z535.2 standard is valuable and correct. The older “OSHA” style safety
sign and tag formats do not use the human factors technology and court-driven legal definitions for what constitutes an “adequate
warning.” They lack the content that better motivates people to avoid hazards. The older signs typically contain half of the
information that is necessary and rarely use graphical symbols to draw attention to their safety message and to communicate across
language barriers. And so change is necessary. People need to be better protected from risk and injury and the newer ANSI Z535
warnings technology is fundamentally better. So it should be used in preference to OSHA’s current regulations.
Back to the question, if you use the new formats will you be in compliance with OSHA? The answer is YES.
Here’s how it works . . . OSHA has an understanding in place where workplace owners can adopt newer “best practices” as defined
by the latest version of the standard on which the original OSHA regulation was based. If you have an OSHA audit and they see your
new signs, they should be pleased to see you are using the best and the brightest, so to speak. In their report OSHA will call this
a “de minimis” violation which only means you are not in step with their antiquated sign regulations and this so-called violation will
not result in a fine. In this way OSHA does not deter a facility owner’s desire to comply with the best industry safety practices as
defined by the latest version of the documents on which their original regulations were based.
This means that the ANSI Z535.2 Standard is acceptable to OSHA. OSHA does not update their documents
whenever a standard changes and this strategy for acceptance of the latest safety technology allows OSHA to not have to go
through what can be a highly involved process to change regulations – and it gives them the ability to encourage the use of best
practices in safety.
Why is incorporating the use of the ANSI Z535 standards into your company’s product design process a good idea?
If you are making a product that has risk associated with it at any point in its lifecycle, from installation and use to maintenance
and disposal, you need to communicate those risks to the people who may come in contact with them. The ANSI Z535 standards,
especially the ANSI Z535.4 and ANSI Z535.6 standards, are your tools for accomplishing this job.
Here’s how it works: Warnings come into play when residual risks remain. Your job as the product design engineer is to make sure
your product’s warnings are conveyed correctly – both on your product’s safety labels and in your product’s instructional information.
(For more information on an informative course on warnings and instructions offered by the University of Wisconsin’s engineering
department, click here ). Since the ANSI Z535 standards are recognized by both U.S. courts and warnings experts as the
state-of-the-art for defining how best to communicate warnings, you should use the
ANSI Z535.4 Standard for Product Safety Signs and Labels for your on-product warnings and the
ANSI Z535.6 Standard for Product Safety Information in Product Manuals, Instructions and Other Collateral Materials
for formatting the safety messages associated with your products.
These two standards will help you to understand the level of content you should consider for your warnings, your formatting options,
specific color specifications you should meet, information about how you can use symbols to convey all or part of your safety message
and many other factors. In the U.S. if you don’t use these standards or if you use them but don’t use them well, and someone gets
hurt using your product, you will likely find your company sued for either “inadequate warnings” or the “failure to warn.” It’s been
estimated that upwards of 40% of all products liability litigation in the United States contains one or both of these “defective
warnings” allegations. U.S. courts often use the
ANSI Z535.4 Standard for Product Safety Signs and Labels as the benchmark
reference in deciding whether or not a product’s safety label was in compliance with the accepted best practices at the time the
product was placed into the market. So making good standards-based decisions for your warning labels makes good business sense
if your interest is to stay in business.
Another important note: Your obligation from a legal perspective is to always use the latest version
of the standards related to your
product when you design and manufacture it. Why? Because you will be held accountable to those standards as “industry best
practices” if and when a lawsuit ever occurs.
Good. So now you’ve decided to use the latest version of the ANSI Z535.4 standard for your product safety labels. Your intentions,
though, are not just about being able to better defend lawsuits. Your first and foremost goal is to reduce the chance of accidents,
injuries and deaths occurring in the first place. To achieve this goal, you’ll want to apply the technology contained in the ANSI Z535
standards to its maximum potential. Note that it is not just the Z535.4 labeling standard and Z535.6 manuals standard that should
be considered here – the color standard (ANSI Z535.1) and symbol standard (ANSI Z535.3) also play a role in a good product risk
communication/risk reduction warnings program. Getting up to speed on these standards and how they interact with each other
and with their international counterparts (ISO and IEC standards) is what Clarion brings to your team (as well as the actual design
and production services necessary to manufacture your safety signs and labels). We’re here to help you better communicate risk and a
Clarion Compliance Specialist is just a phone call away at 800-748-0241.
What is "state-of-the-art?"
"State-of-the-art" is a term that has many definitions. However, in the area of safety markings, courts typically use this term to mean
that your safety signs and labels were designed according to the requirements set forth by the most current industry-accepted best
practice standards that were in effect at the time your product was manufactured. Standards change and are revised. So it is
important to stay on top of things as you go about the process of designing and manufacturing your products. We encourage you
to use this website and the Clarion staff as your resource to accomplish this objective as it relates to safety signs, labels and
markings.
Why should I comply with ISO standards?
Meeting current international safety labeling requirements is an important part of preparing your product for export. First understand
that 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 run the risk of having your equipment
failing inspection, which can mean that it cannot be sold or installed in the European Community. Other nations outside of Europe are
putting similar requirements in place. So this is why developing a warnings program that is consistent with both U.S. and
international requirements is very important. A good warnings program will help your products to be sold around the world and that,
in itself, helps your company to prosper in all of its markets.
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 what makes Clarion Safety Systems unique in its field. Because we hold leadership positions on the two principle
standards-making bodies in this area (ANSI and ISO) and because we participate in many industry-specific safety label standardization
efforts, our expertise in this area is unparalleled. To receive updates on issues pertinent to safety signs and labels, register here for
our information-packed email newsletter.
Do product manufacturers need to retrofit existing products out in the field with new safety labels that are up-to-date with today's standards?
If your product safety labels clearly do not meet the latest version of the ANSI Z535.4 standard, this becomes an obvious and
important question to consider. Overall, you’ll want to look at whether your products’ old safety signs and labels adequately
communicate the safety information defined by today's ANSI and ISO standards, court precedents, your company’s products’ accident
history, industry safety developments, accidents with similar products, and the like. If your safety markings are inadequate by these
measures, you may be unnecessarily exposing your company and your product users to risk – and that can be lawsuit material. In the
interest of being a “good corporate citizen” – that is, a safety conscious company that does what is needed to protect people from
harm -- your product safety labels need to be part of the risk-reduction solution, not a glaringly out-of-date potential safety and
litigation problem.
From a product manufacturer's perspective, there are many considerations when deciding to undertake a safety label retrofit program.
What’s possible? What’s reasonable? Do you know where your products are? Do you know who to send replacement labels to? Are
there one or more means of contacting those who may use or come in contact with your product? From a legal point of view, you will
be held to the measure of “what is reasonable.” Choosing to send out new labels to retrofit your products in the field can be simple,
so you can do it yourself. Or it can be complex and you need the help of a company that knows how to properly handle a recall. See
our Clarion Resource page for experts in product recall. Again, determining what is reasonable will be the key.
Do facility owners need to change their facility safety signs to be up-to-date with today's standards?
From a facility owner's perspective, effectively informing people (which means not only employees but also subcontractors and visitors) of safety-related issues in and around your facility is the key to reducing the possibility that accidents could happen, and also to avoiding costly litigation centered on negligence and premises liability. Your goal must be to keep people safe from harm. Using the most up-to-date warnings technology as exemplified by the latest standards in this area is your duty and our area of expertise. At Clarion, we fully understand the components that go into a unified visual risk communication program. Our system of signs and markings include:
All of these components play an essential role in your company's effort to keep people safe. Clarion’s knowledge and experience in
this particular field is unparalleled. We look forward to helping you to adopt the latest in risk communication best practices so your
company can achieve the goal of better protecting people and reducing risk.