The content and format of your product's safety signs and labels is incredibly important. The mistake of having incomplete content and the wrong formats can lead to accidents that result in personal injuries, deaths, property damage, and the litigation that often follows from such occurrences. That's why determining the proper content for your product safety labels is a serious matter and one that deserves your utmost attention.
Step One: Recognize that your company's legal obligation is to meet or exceed the current standards that apply to your products, and this includes the latest American National Standard on safety labeling (ANSI Z535.4 – 2007, though the every-five-year revision of this standard will be published next year...stay tuned to my blog to get an overview of the new version of the ANSI standards prior to their release). Back to the topic at hand...your warning labels. They need to be up-to-date or you could be faced with a plaintiff's attorney challenging your efforts in court with a solid argument that your product safety labels are "inadequate" and that you did not meet your legal "duty to warn" all because they were not compliant with the standards in effect at the time your product was manufactured.
Step Two: As you scope out your safety label project, recognize right off the bat that the need is not to develop a safety label for one of your products (or, for that matter, if you have multiple products the task is not to develop all the safety labels for just one of your products). The need is to create a safety label program for your entire line of products, addressing the needs for all of your anticipated markets (foreign and domestic). Why? Because the ramifications of doing a half-way job in this critical engineering exercise exposes your company to an incredibly high degree of risk when it comes to liability loss exposure. "Ladies and gentlemen of the jury, look at this company's efforts...they saw fit to update their labeling on this product but not the one that severely injured my client." You do not want to be put in this situation. Ask any defense attorney worth his salt, an overall corporate-wide safety labeling perspective is your correct goal.
Step Three: Understand what's required to get this job done right. In short, what you need is collaboration with product safety labeling experts. Why? Let me explain. When you're creating safety labels, you need:
- A thorough knowledge of all six of the ANSI Z535 standards and the ISO standards applicable to your type of product. This family of ANSI and ISO standards is intertwined in both its foundational principles and its application across nearly the entire field of hazard communication. You need to know these standards inside and out to apply them purposefully and correctly.
- You need to know how these safety label standards have already been applied to the hazards you need to address on your products, and this does not just mean a quick look at your competitors' labels. It means you need to know how the ANSI and ISO standards have been practically implemented across a range of industries for the potentially hazardous situations you're trying to warn about. Believe me, there are commonalities among the safety labels used on semiconductor manufacturing equipment and on the equipment used in slaughter houses. I've been in both environments and I've developed the safety labels used for both industries. Semiconductor fabrication plant clean rooms and slaughter houses have more in common than you'd think! Contamination issues, sterilization procedures, PPE requirements, exposure to chemicals...the list is actually pretty lengthy. Cross-industry knowledge about how warnings are crafted for specific hazards is a great advantage when the job is to create safety labels that will effectively communicate their message and be judged as "adequate" in a court of law.
- You need to know how ANSI and ISO standards harmonization has occurred, where harmonization activities are going, and how you can best use the "harmonized" provisions in these standards to your best advantage to meet all of your products market ("intended users" is the legal term). Because of my leadership positions on both the ANSI and ISO safety labeling committees, seeing the harmonization effort through to a good conclusion has been my passion for the last 15 years. Thankfully, the direction we're headed in now couldn't be better for product manufacturers. The hours, days, weeks and literally years I've spent hammering out solutions in subcommittee meetings held all over the place have been worth it because we're at the point where we're making the world a safer place.
As a design engineer, your expertise is in the development of the products for your company. As a risk manager, your expertise is in mitigating risk. At Clarion, our expertise is in the design and manufacture of safety signs and labels, and of the standards that govern the establishment of best practices. We've done safety label programs for over 10,000 manufacturers and we know that collaborating with us, the experts in this field, will save your company significant money. Not only will the project be completed more efficiently, but it will also be done correctly. The dollar savings are even larger when you factor in the intended results of your program: engineering the final product to have state-of-the-art standards-compliant warnings on it whose purpose is to prevent accidents from occurring. Such warnings also serve to significantly improve your defense position should an accident occur and a lawsuit be filed. "Case dismissed." "Not guilty." Those are the words you should hear when you're able to prove to the judge or jury that your product had adequate warnings, warnings that the U.S. courts allow you to assume that the client should have read and obeyed.