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Edit date: June 20, 2008 Issue date: June 28, 2002

The ANSI Z535.4-2002 Revision Is Set for Release: Major changes are occurring in U.S. safety sign and label standards beginning July 1, 2002

By Geoffrey Peckham


Awareness of the newly revised standard is the purpose of the following information. The staff at Clarion Safety Systems (Clarion) is ready to provide your company with state-of-the-art labels that meet the latest version of the ANSI Z535.4 standard and we look forward to your contacting us at your earliest convenience. At Clarion we make the conversion to new compliant safety labels an efficient process that will allow your company to have the latest in safety labeling on your equipment in a matter of days, not months. Call our Customer Service Dept. at 800-7480241 or send us a quick email and we will respond promptly.

Safety Labels ­ A Critical Component Part of Your Product

Safety signs and labels play an important function on the products your company designs and builds. The job of a safety label is to alert persons to residual hazards and explain how to avoid those hazards. If designed correctly and its message followed, a safety label alerts the product user of potential hazards and protects them from harm. If an accident does occur, the safety label functions to protect your company from product liability litigation exposure. It is estimated that the allegations of "inadequate warnings" and failure to warn" are included in over 70% of the product liability lawsuits that occur in the United States. This being the case, safety labels have become a critical component part to many products, especially capital equipment such as industrial/commercial machinery.

Why You Must Use the Latest Version of the ANSI Z535.4 Standard

Meeting current standards is a manufacturer's legal responsibility. The new American National Standards Institutes' ANSI Z535.4 ­ 2002 Product Safety Sign and Label standard will be published and in effect on July 1, 2002 (call Global Engineering Documents to purchase a copy, 800-854-7179). For the past 12 years this standard has set forth the requirements for product safety labels in the U.S. Revisions to this standard should be reflected in the design of your products' safety labels. Outdated labels broadcast the fact that your products don't meet current standards! The intent of this white paper is to bring important developments in the ANSI safety labeling standards to the attention of those who specify product safety labels for their company's products. In the United States you need to use American National Standards Institute's Z535 standards because they are the measure U.S. courts use to determine the "state-of-the-art." Although the Z535.4 Product Safety Sign and Label standard 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 the current version of this standard. The net effect is that you can choose not to abide by the latest version of the Z535.4 standard but sometime in the future you may need to substantiate your reasons why you believe your actions "exceeded" the standard. This is not a

Clarion Safety Systems, LLC · 190 Old Milford, P.O. Box 1174, Milford, PA 18337 · ph (800) 748-0241 · fax (800) 748-0536 ©2007 Clarion Safety Systems, LLC All rights reserved ·


situation you want to put your company in given the ease in which a jury can compare a "good" safety label (one that has the proper format and content) to your "old" safety label that has neither the proper format or content.

The Revision Cycle ­ How Changes Occur

Every five years the ANSI Z535 standards must be reviewed, updated as necessary and republished. If this process is not done, a standard risks being rescinded. The objective of this process is to keep the ANSI Z535 standards current and up-to-date with the latest technology available. During the course of the five-year revision cycle the Z535 committee is open to accepting change proposals. Each proposal goes through a rigorous review process and in the end, is either accepted, modified or rejected. ANSI has set procedures for this process and the Z535 committee is run in strict accordance with ANSI's rules. Clarion has been a very active member of the Z535 committee since 1992. The president of Clarion, Geoffrey Peckham, is Chairman of the ANSI Z535.1 subcommittee and has been the principle author of many of the changes that have been accepted for both the 1998 and 2002 ANSI Z535.4 revisions.

Important Changes in the ANSI Z535.4 Standard- 2002 Revision

Change No. 1 - Formats

The 2002 revision of the ANSI Z535 standards makes obsolete the old ANSI Z35 sign formats that have been in use for many years (see Figure 1).

Figure 1. Examples of the formats made obsolete by the 2002 revision of the ANSI Z535 Standards

In the 1991 version of the Z535 standards, the old Z35 style signs were kept; they appeared in the ANSI Z535.2 Standard for Environmental and Facility Safety Signs and the ANSI Z535.5 Standard for Accident Prevention Tags. As an exception, the ANSI Z535.4 Standard for Product Safety Signs and Labels allowed the Z35 formats to be used for product safety labels if the product manufacturer so desired. In the 1998 revision of the ANSI Z535 standards the Z35 formats were again maintained in the Z535.2 and Z535.5 standards but they became the "alternate" format for safety signs and tags. The ANSI Z535.4 product safety label format was the "preferred" format to follow in all of the standards. Now, five years later, the ANSI Z535 2002 revision has finally eliminated the old Z35 formats! The formats once only found in the Z535.4 product safety label standard are now the only formats allowed in all of the Z535 standards (see Figure 2).

Clarion Safety Systems, LLC · 190 Old Milford, P.O. Box 1174, Milford, PA 18337 · ph (800) 748-0241 · fax (800) 748-0536 ©2007 Clarion Safety Systems, LLC All rights reserved ·


Figure 2. Proper 2002 ANSI Z535 safety sign, label and tag formats (shown in vertical formats)

The following are the primary reasons why the Z535 committee removed the old formats: 1. The structure of the Z535.4 format easily accommodates symbols ­ an element that is becoming more and more important as the world moves towards the use of symbols to communicate information. 2. This format easily accommodates more information ­ a fact that is extremely important because having the right concise (and complete) message on your product safety label is the key to providing your product with "adequate" warnings (see above on the legal ramifications of warnings). The Z535.4 standard says that a product safety label should communicate: · · · · the type of hazard the seriousness of the hazard the consequence of interaction with the hazard and how to avoid the hazard.

Signs and labels formatted in the old Z53 style rarely communicate all of this information. 3. Removing the colored background from the text portion of the old orange WARNING and old yellow CAUTION signs makes the word message more legible. 4. The Z535.4 format includes the safety alert symbol (a triangle with an exclamation mark). This symbol signifies that there is a personal injury hazard and it appears to the left of the signal word DANGER, WARNING or CAUTION. The 2002 ANSI Z535 standards revision makes this symbol a universal element on all U.S. personal injury-related safety signs and labels. 5. This change institutes the goal of a national uniform system for hazard recognition - one of the primary objectives for standardization for the ANSI Z535 committee. Over time there will be a consistent look to all of the signs on walls, the signs and labels that appear on products, and the formats for temporary safety tags.

Clarion Safety Systems, LLC · 190 Old Milford, P.O. Box 1174, Milford, PA 18337 · ph (800) 748-0241 · fax (800) 748-0536 ©2007 Clarion Safety Systems, LLC All rights reserved ·


Conclusion on Formats: Companies that use the old Z35 formats should now make the change to safety signs and labels that meet the new Z535 standards. If you are currently using labels that are formatted to the old Z35 standard, you should do two things: 1) Make the change now to labels formatted to meet the ANSI Z535.4 ­ 2002 standard for all products shipped from this point forward! This must be a top priority for your company. Throw away inventory of the old labels. To do otherwise is to risk serious product liability exposure ­ your company could easily be found guilty of the "failure to warn." As noted above, your duty is to meet or exceed current standards requirements for product safety labels and using the old Z35-formatted labels will be viewed in any future product liability lawsuit as a failure of your company to adequately warn because you did not comply with the current standard. 2) Consult your company's legal council to determine whether a safety label retrofit on Existing equipment in the field is recommended. This may or may not be necessary depending on your legal consultant's opinion concerning the adequacy of your warnings.

A Note on OSHA Regulations

Oftentimes people ask whether it isn't OSHA that mandates safety sign standards for equipment used in the workplace, not ANSI. The answer to this question is that compliance with ANSI Z535 is the correct choice. The reasoning behind this answer is that the OSHA regulation for safety signs (1910.144), written in the 1970's, was based on the ANSI Z53 Safety Color Code and Z35 Safety Sign Standards. The committees responsible for these standards were combined in 1979 to form the ANSI Z535 committee. When the ANSI Z535 series of standards were first published in 1991 they replaced the Z53 and Z35 documents. The ruling that OSHA takes is that if you comply with the latest version of the "basis documents," you are in compliance with the OSHA regulation! The latest version of the Z535 standards are therefore the right design guidelines to follow to comply with OSHA since their precursors were the basis documents for OSHA's 1910.144 regulation. OSHA regulations are not updated on a periodic basis (like the ANSI standards) and that is the reason OSHA allows for the acceptance of compliance with basis documents. (Example comparisons are made of old and new labels on the next page.)

Clarion Safety Systems, LLC · 190 Old Milford, P.O. Box 1174, Milford, PA 18337 · ph (800) 748-0241 · fax (800) 748-0536 ©2007 Clarion Safety Systems, LLC All rights reserved ·


Do NOT touch.

Figure 3. Old and new safety label examples. Note that the new labels are shown in the horizontal format. New labels should convey specific hazard nature, consequence and avoidance information.

It is important that everyone in your organization who specifies safety labeling should be made aware of this change so that your company and all of its divisions can immediately make the transition to current compliant safety labels. To do otherwise is to make your product less than "state-of-the-art," thereby placing your company at risk for future product liability litigation. Call Clarion to assist you with the conversion to new 2002 compliant labels.

Change No. 2 - On Symbol Use and Validation for Recognition

From the legal "human factors" perspective, the crux of the issue seems always to revolve around the issue of whether or not your product's safety label adequately communicates all of the Z535.4 items of content. And, if not, can the remaining content be inferred from the context in which the safety label is used (i.e. the location on the equipment, the environment of use, etc.). Symbols play an increasingly important role in the field of safety communication. In short, they represent the state-of-the-art because they have the ability to efficiently communicate across the barriers of languages and illiteracy. About 90% of the labels Clarion manufactures for equipment manufacturers contain one or more symbols! In the 1998 version of the ANSI Z535.4 standard the section on symbol use stated the following:

Clarion Safety Systems, LLC · 190 Old Milford, P.O. Box 1174, Milford, PA 18337 · ph (800) 748-0241 · fax (800) 748-0536 ©2007 Clarion Safety Systems, LLC All rights reserved ·


(1998) Section 11.2 Symbol/pictorial use "Symbols and pictorials may be used to clarify, supplement or substitute for a portion of a word message found in the message panel of product safety signs. Only symbols validated for recognition should be used. Symbols/pictorials that have not been validated for recognition may only be used to supplement or clarify the word message on the product safety sign." The problem with this section was that it did not define what was meant by the words "validated for recognition." Was the standard trying to say that all symbols that intend to replace word messages must be tested for comprehension? Or was it saying that if a symbol was recognized by an authority (such as another standards body), it could be used to replace words? By not defining "validated for recognition" the standard sidestepped the issue of symbol comprehension requirements. In the 2002 revision of the Z535.4 standard this section was revised to say the following: (2002) Section 11.2 Safety symbol use "Safety symbols may be used to clarify, supplement or substitute for a portion or all of a word message found in the message panel. A symbol may only be used to substitute for a portion or all of a word message if it has been demonstrated to be satisfactorily comprehended (e.g., Annex B of ANSI Z535.3) or there is a means (e.g., instructions, training materials, manuals, etc.) to inform people of the symbol's meaning." Here are the changes in this section point by point: 1. In comparison to the 1998 version of the standard, there was a vocabulary change: "safety symbols" replaces symbols/pictorials" throughout the standard. 2. The 1998 version's sentence that included "validated for recognition" was removed. 3. The 2002 version now says that a symbol can replace a portion or all of a word message. This fact was buried in the 1998 version in section 6. Panels and very few people knew that the standard allowed symbols to replace the entire word message. 4. The 2002 revision clarified when a symbol can be substituted for words. Either the symbol needs to pass comprehension testing (ANSI Z535.3) or you use another means to inform people of its meaning. This is one of the most important changes embodied in the 2002 revision to ANSI Z535.4. Finally there is recognition that there are other "means" to inform people of a symbol's meaning. Training becomes a viable solution. Education about the meaning of symbols should always be viewed as an essential ingredient in the safety process. Clarion's president, Geoffrey Peckham, chairs the U.S. delegation to the ISO standards committee in charge of safety signs and labels and he notes that the European safety sign system is one that is dependant on symbols and education. The hope is that once trained, people will recognize the symbols the next time they see them. The net result will probably be that most U.S. manufacturers will use this revised section of the ANSI Z535.4 standard to back up their decision to explain the meaning of their safety symbols in their operation and maintenance manuals rather than test symbols. Training becomes a viable means to promote symbol comprehension. Clarion makes available to its customers electronic images needed for inclusion in product manuals to promote safety symbol education.

Clarion Safety Systems, LLC · 190 Old Milford, P.O. Box 1174, Milford, PA 18337 · ph (800) 748-0241 · fax (800) 748-0536 ©2007 Clarion Safety Systems, LLC All rights reserved ·


Change No. 3 ­ Standardization of Translated Signal Words

During this revision cycle a change proposal was made to the ANSI Z535 committee to include Spanish translations for the signal words DANGER, WARNING and CAUTION in an annex in each of the Z535.2, Z535.4 and Z535.5 standards. The president of Clarion, Geoffrey Peckham, suggested that this would be a wrong move because it would give the impression that Spanish translated bilingual safety signs, labels and tags were expected as the norm in the United States. Instead Mr. Peckham proposed that an annex be added to the standards that dealt with signal word translations and that it include sixteen additional languages. Not only would such an annex be more useful, it would not infer that Spanish was the only additional language to consider for safety messages. This proposal was accepted and the work already done by the U.S. TAG to ISO/TC 145 (a committee chaired by Mr. Peckham) was accepted as the basis for this annex. This decision is consistent with the decision for the 1998 revision of the ANSI Z535.2 and Z535.4 standards to qualify Annex B section B5 Multi-lingual formats with the following words: "The selection of additional languages for product safety signs is an extremely complex issue. Experts suggest that nearly 150 foreign languages are spoken in the United States and over 23 million Americans speak a language other than English in their homes. If it is determined that additional languages are desired on a safety sign, the following formats may be considered." This text makes it clear that it is a company decision as to whether or not to provide additional languages on their safety labels (i.e. it is not a requirement of the Z535.4 standard). The new annex includes the signal words DANGER, WARNING and CAUTION in the following languages: Chinese, Danish, Dutch, Finnish, French, German, Greek, Italian, Japanese, Korean, Norwegian, Portuguese, Russian, Spanish, Swedish and Turkish. Another benefit of having these standardized translated signal words is for companies wishing to export their products from the U.S. using their ANSI Z535.4 labels translated into the language of the country to where the product will be used. Note that Clarion routinely produces labels in all of these languages as well as Hungarian, Thai and several other languages.

Change No. 4 Harmonization with ISO

In standards-writing vocabulary, harmonization means the bringing together of various standards requirements so that a given set of standards are unified. Harmonized standards share common general requirements, though details may differ. The Z535 committee discussed at length the idea of incorporating ISO symbol-only formats into the 2002 revision of ANSI Z535.4 standard. Points "for" the inclusion of such formats include: · A good portion of the rest of the world has accepting these formats.

Clarion Safety Systems, LLC · 190 Old Milford, P.O. Box 1174, Milford, PA 18337 · ph (800) 748-0241 · fax (800) 748-0536 ©2007 Clarion Safety Systems, LLC All rights reserved ·



The marketplace is now a "world" market, not a local market, and manufacturers must ship their products worldwide. Having different safety labeling systems is a barrier. ANSI has asked all U.S. standards committees to consider harmonization with the international ISO and IEC standards when possible. The U.S. TAG to ISO/TC 145 (chaired by Clarion's president Geoffrey Peckham) has made progress in having many of the general requirements that appear in the ANSI Z535.4 standard included in the revision of ISO 3864 ­2 (a standard now in draft form for product safety labels). In turn, the U.S. should consider including ISO formats in the ANSI standards.

· ·

The points against including the ISO formats in the ANSI Z535.4 standard include: · · The symbol-only formats do not convey seriousness level (i.e. they do not contain a signal word) The ISO standards include many symbols which have not passed comprehension testing. Allowing U.S. manufacturers to use these symbols on their products would degrade safety. There are only a few legal precedents that have said that a symbol-only warning is adequate. Allowing the ISO formats is a step backwards when trying to achieve a single national uniform system for communicating hazard information ­ something the U.S. is growing closer to achieving with the elimination of the old Z35 formats described in Change No. 1 above.

· ·

The Decision: The Z535 committee weighed all of the above points and decided that it would not include ISO formats in this revision of the standards. This topic will be considered again for the 2006-7 revision. To indicate this, an Annex C was added to the ANSI Z535.4 standard that says: "ISO standards such as ISO 3864 and other ISO industry-specific standards exist for product safety signs and labels. These ISO-formatted safety signs have been used internationally for many years. In some instances, it may be possible for a safety sign or label to be in conformance with ANSI Z535.4 and an ISO standard. In other instances, conformance with one standard will not result in conformance with one or more aspects of the other. A decision to convey all or a portion of a product's safety information in the form of ISO formatted signs may be based on many factors. Such factors include, but are not limited to, the product's anticipated market, the movement of the product from country to country during its expected life, the target audience's characteristics, and space availability on the product. Harmonization activities between ANSI Z535 and ISO standards have been on-going since 1995 and the next revision of ANSI Z535.4 will reflect the latest developments in this effort." Note: The president of Clarion, Geoffrey Peckham, is on the ANSI Z535 committee and chairs the U.S. TAG to ISO/TC 145, the committee in charge of ISO 3864. For seven years he has

Clarion Safety Systems, LLC · 190 Old Milford, P.O. Box 1174, Milford, PA 18337 · ph (800) 748-0241 · fax (800) 748-0536 ©2007 Clarion Safety Systems, LLC All rights reserved ·


been working diligently to bring about the harmonization of these standards so manufacturers have a full range of options to choose from ­ making it possible for them to be in compliance with both U.S. and international standards.

Clarion ­ Making it easy to update to the new label requirements

Clarion hopes that the above information has been helpful to you as your company plans to revise its safety labels to comply with the new standards. Choose from one of the 10,000+ safety label designs we have in our database! Or use Clarion's custom design services at - in four easy steps we can custom design your labels. Clarion's efficient ordering and design services can literally transform your obsolete label inventory into new compliant labels in a matter of days, not weeks or months. See what our customers say about the value Clarion brings to this process at . Too much is at stake not to use the best company in the world when it comes to safety labels! Clarion ­ The safety label experts. Welook forward to serving your company in the very near future.

About the Author

Geoffrey Peckham is president of Hazard Communication Systems, LLC, the world's leading product safety label design and manufacturing company. He has been an active member of the ANSI Z535 committee since 1992, has chaired the Z535.1 subcommittee since 1994, and, since 1996, has chaired the U.S. TAG (delegation) to ISO/TC 145, the international committee responsible for the safety sign, color and symbol standards issued by the ISO (International Organization for Standardization).

Clarion Safety Systems, LLC · 190 Old Milford, P.O. Box 1174, Milford, PA 18337 · ph (800) 748-0241 · fax (800) 748-0536 ©2007 Clarion Safety Systems, LLC All rights reserved ·



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