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Session No.

517

A New and Powerful Risk Reduction Technique:
Creating OSHA/ANSI Safety Sign Systems as an Outcome of
Risk Assessment
Geoffrey Peckham
Chair, ANSI Z535 Committee
CEO, Clarion Safety Systems, LLC
Milford, PA

Introduction
As safety professionals, we share a common goal: to reduce accidental injuries and deaths. We all
strive to create safer work environments to prevent workplace fatalities, injuries and illnesses. There
are now two powerful new tools available to assist us in this effort:
1. the latest risk assessment standards
2. the new ruling made by OSHA in 2013 to incorporate the latest ANSI Z535 sign standards into
their general (1910) and construction (1926) regulations.
This session will explore these two new tools and how safety professionals can apply them at
workplaces, job sites and in public environments to better protect people and reduce risk.

The Rise of Liability Exposure and Warnings
The legal “duty to warn” is a concept of law that has been shaped over the past 60 years, beginning in
the field of products liability litigation. A series of court cases between 1950 and 1980 established
that manufacturers of products have the responsibility to put non-defective, reasonably safe products
into the marketplace. As the law in most States is now written, product manufacturers must design out
residual hazards associated with the reasonably foreseeable use and misuse of their products, or if
designing out the hazards cannot be done, guarding people from them, or if that cannot be done,
warning people about them. If they fail to do this, the product can be found to be defective in a
products liability lawsuit and the manufacturer found guilty and subject to judgment. As a direct
result of the evolution of products liability law, the ANSI Z535.4 Standard for Product Safety Signs
and Labels was written and first published in the early 1990s. Over the past twenty plus years, this
standard has gained wide acceptance among product manufacturers in nearly all industries as the “goto” source for understanding how best to construct a product safety label. Even though allegations of
“inadequate warnings” and “failure to warn” continue to top the list in product liability lawsuits
today, manufacturers that intelligently use the ANSI Z535.4 standard have a vastly improved ability
to defend themselves in such litigation.

vastly improved bar for visual risk communication. The OSHA rule change is significant because it establishes a new. rank them in terms of priority. This “raising of the bar” is a direct reflection of our society’s increasing expectation for accurate risk communication. involving fewer employees An increased use of subcontractors in workplaces and job sites An increased use of temporary workers in workplaces and job sites Rising costs for workers’ compensation The increasing creativity of lawyers to find ways to bring suit against companies and municipalities on behalf of injured parties The recent publication of risk assessment best practice standards The rising cost of general liability insurance and health insurance The Rise of Risk Assessment The above factors are forcing safety professionals and risk managers to stay on top of their game – too much is at stake to do otherwise. best practice warnings technology as defined in the ANSI Z535-2011 safety sign and tag standards. Fortunately. Intelligently designed signs and tags in compliance with these standards provide safety professionals with the ability to: • • • • More effectively reinforce safety training programs with permanent visual reminders of hazards and precautionary steps to avoid hazards Provide more substantive safety messages on safety signs and tags Use the ANSI Z535 standards’ human factors and risk assessment-based concepts to more accurately convey safety messages Use multiple language panels and graphical symbols to better communicate safety to broader target audiences Whether the task is creating a safer product. Consider these factors in the United States: • • • • • • • • Increased litigation in the area of premises liability and the lack of warnings A shift in manufacturing to ever-more complex equipment. The Intersection of Risk Assessment and the New OSHA Safety Sign Systems The new OSHA 2013 sign systems take advantage of the latest. The process outlined in these standards helps safety and risk professionals to effectively identify hazards. and then develop and determine risk reduction measures to create a safer product. the development of new OSHA/ANSI safety sign systems is an important outcome of your risk . a safer workplace or a safer public environment. OSHA made an important change to its standards related to workplace safety signage: it updated its safety sign and tag regulations to incorporate the current ANSI Z535 (2011) standards as cited references wherever safety sign and tag requirements are stated. If you choose not to meet this bar. workplace or public environment.The 2013 OSHA Sign Change and Its Effect In the fall of 2013. the last point on the list above provides a solution: the new risk assessment standards. This seemingly small change is incredibly important to those in charge of safety and risk management systems. you will more than likely be unnecessarily exposing your company to litigation should an accident occur.

The acceptance by OSHA of references to the current ANSI standards in their regulations in September of 2013 completely eliminates this “de minimis violation” situation—you are now perfectly able to use the new ANSI standards for signs and tags and you will be in compliance with the latest OSHA rules.2 project is not a hodge-podge set of signs that get stuck up on the wall.2 standard lays out a systematic approach to communicating safety.2 standard requires the people designing the system to consider safety signage as a “system” of visual communication. it can improve communication so that people make better decisions about actions that might otherwise get them injured or killed. and fewer fatalities in nearly every industry.2-2011 Standard’s “System” of Signs It’s important to understand that the ANSI Z535. It’s also important to understand that the 2011 ANSI Z535. The promise of the new safety sign technology is that when it’s done well. In fact. and you had an OSHA inspection.assessment process. Yet up until September 11. and posts. the warnings technology that has been developed over the past 30 years has not been widely used for safety signs in the American workplace. 1. During our discussions. on fences. just the opposite occurred. The end result of a well-defined ANSI Z535. what OSHA calls. Instead.1) . Improving safety to minimize injuries and deaths is the number one goal. The ANSI Z535. The goal of updating the OSHA standards as they relate to safety signs is that better safety communication at the point where someone may interact with a hazard will lead to fewer accidents. But because you were using the latest versions of the older standards on which OSHA had based its regulations. 2013. The ANSI Z535.2 standard for signs utilizes a “system” of design elements that are aligned with the other five standards that make up the family of ANSI Z535 standards. in both public and private venues. a “system” that is built in three ways. you would not be subject to a fine. As a group. prior to September 2013. but your documentation would still show. OSHA’s non-acceptance of the latest ANSI standards for safety signage actually was a deterrent to their use. In short. outside facilities. walls. fewer injuries. OSHA did not reference the most recent safety sign and tag standards—as a consequence. The situation was that the way OSHA works. But if an accident does occur. That’s the critical role safety signs play in the workplace—giving people the information they need to make wise decisions to prevent accidents. the documentation that goes into your risk assessment and the design of your OSHA/ANSI Z535 safety sign system will become one of your company’s most critical defense documents should a lawsuit occur. it applies to practically every safety sign you encounter in workplace and public space environments. a “de minimis” violation. these standards are the primary A-level standards used in the United States for communicating safety information in a visual format. use of the ANSI Z535. you would be found to be in violation of OSHA regulations.2 standard applies to all safety signs installed inside facilities. OSHA recognized that the threat of receiving a de minimis violation probably put most employers off on the idea of updating their signs to meet the latest best practices as defined by ANSI standards. The larger picture here is to understand that OSHA is trying to improve safety communication in the workplace. if you were an employer that used the newer ANSI Z535 standards for your safety signs and tags. The six standards cover the following topics: • safety colors (ANSI Z535.

Each of these three signal words communicates a different level of risk (risk being defined as a combination of severity of injury and probability of the accident/injury occurring if the sign’s message is ignored). that when used together. you will see how your plant’s safety signs work in combination with one another to convey safety in a variety of ways. The first category of signs is “hazard alerting” signs. create a system of signage intended to reduce risk and protect people. distilling them out of the background of the thousands of messages they see on a daily basis.4) temporary tags and barricade tapes (ANSI Z535. taken together. each with their own distinct purpose. Those responsible for safety must understand how to apply these design principles. Once the categorization system is understood. WARNING or CAUTION on the top of the sign to catch people’s attention and inform them that they need to be aware of a nearby hazard. When you understand this structure. The ANSI Z535. people will more easily notice.• • • • • environmental/facility safety signs (ANSI Z535.2 Categories of Signs There are four categories of safety signs according to the ANSI Z535. 3. . recognize and understand safety messages.2-2011 standard. • DANGER is used to indicate a hazardous situation which. These signs use the large colored signal words DANGER.6) The theory behind standardizing a system of design components for safety signs is that through the common use of uniform principles for layout. The overall goal for all of the individual company efforts in this area is to create a national uniform system for hazard recognition and this can only be done through the consistent application of the ANSI Z535 system of design principles.2 sign system works is to see how the different sign categories are defined and what they look like. Each of these types of signs will be described below.3) product safety signs and labels (ANSI Z535. 2. below is underlined so the reader will see how the interplay of injury severity and probability combine to indicate a distinct level of risk severity for each hazard alerting sign. The words in each ANSI Z535 signal word definition. The ANSI Z535. can effectively communicate safety in public and private environments. In the end. looking at them as a system of interwoven components that.2 standard establishes clearly defined “categories” of safety signs. you will see why the ANSI Z535 system is significantly better at communicating safety messages than the older sign formats that may still be in use at your facility.2 sign has a systematic structure to it. Hazard Alerting Signs – Signal word selection The best place to start to understand how the ANSI Z535. if not avoided. This signal word is to be limited to the most extreme situations. will result in death or serious injury.5) safety information presented in product manuals and collateral material (ANSI Z535.2) design and testing criteria for safety symbols (ANSI Z535. a hazard that could result in personal injury or death. your safety signs will play a new and more integral role in your facility’s risk reduction and safety training programs. The content displayed on each type or category of ANSI Z535. color and content.

This old system of accident prevention signs used either DANGER or CAUTION for signal words and the choice of which word to use was based solely on the “immediacy” of the hazard. DANGER or WARNING would be the correct choice for the signal word for high voltage signs because interaction with this type of hazard “will” or “could” result in death or serious injury. Yet interaction with the voltage hazard results in electrocution. And. could result in minor or moderate injury. • CAUTION is used to indicate a hazardous situation which. a standard that was written back in the time when processes were often less complex and modern-day risk assessment methodologies did not exist). applying ANSI Z535 signal word definitions.1 Standard for Accident Prevention Signs (i. . both types of hazards result in “immediate” injury. CAUTION signal words for various types of hazardous situations dovetails nicely into present-day risk reduction methodologies. Not exactly the same level of risk! In the ANSI Z535.• WARNING is used to indicate a hazardous situation which. Exhibit 1.2 sign system is an improvement over the old 1971 OSHA-style signage that was actually first created in 1941 in the ASA Z35. if not avoided. But in one instance interaction with the hazard most often results in a slight burn.2-2011 Signal word panels for hazard alerting safety signs (Older style on left.2 system of signal word risk level communication. Yes. That is why it’s common to see “DANGER—HOT” signs placed in facilities that also have “DANGER—HIGH VOLTAGE” signs installed. This is one reason why the ANSI Z535.e.. the signal word for most burn hazard signs would be CAUTION because the result of interaction with the hazard is usually minor or moderate injury. if not avoided. ISO harmonized style on right—both styles are acceptable) This system of choosing the DANGER. ANSI Z535. could result in death or serious injury. WARNING. It did not take into account the severity of the injury.

Note that both standards allow for information on consequence. and how to avoid the hazard.2 hazard alerting safety sign . it’s necessary for the safety signs on a factory’s walls and the signs posted in public areas to be consistent in their design with safety signs found on consumer and industrial machinery products.2 and ANSI Z535. A person should not be confronted with two distinctly different sign systems. Second. But both standards also caution the reader to consider many factors when deciding whether to omit any of these content components. like the signal words. This is important for several reasons.2-2011 facility hazard alerting signs are defined exactly in the same way that the content components for product hazard alerting signs are defined in the ANSI Z535. use of the ANSI Z535. the content of a hazard alerting sign identifies the hazard. avoidance or type of hazard to be omitted if it can be readily inferred. court decisions that define what constitutes an “adequate” warning. Thus. the level of hazard seriousness. OSHA-style Z35. the content components for ANSI Z535. Example of a typical ANSI Z535. for the sake of achieving a national system of hazard recognition.4 definitions.2 system for defining the proper content for each of your facility’s hazard alerting safety signs should be useful to your company’s liability and litigation position should an accident occur and the issue of whether or not you gave an adequate warning is raised. 2011 ANSI Z535.S. Exhibit 3.Exhibit 2. the probable consequence of involvement with the hazard.2 safety signs (bottom) Hazard Alerting Signs—Content Selection First. having the same safety sign content component structure for facility safety signs is highly important because the ANSI Z535 committee based these content components on human factors research and U.1 safety signs (top).4-2011 Standard for Product Safety Signs and Labels. First. According to the ANSI Z535.

For environmental/facility signs.2 standard is that this type of sign can actually appear as a separate panel on another safety sign. but also how to avoid it. and housekeeping rules. Take the “DANGER—HIGH VOLTAGE” sign. what level of PPE should I wear before performing maintenance on this panel? A well-crafted ANSI Z535.2-2011 Signal word panel for notice safety signs SAFETY INSTRUCTION Signs The third category of safety signs according to the ANSI Z535. the safety alert symbol is not used with this classification of signal word. For these signs.g.. ANSI Z535. Exhibit 4. Again. and if so. NOTICE Signs The second category of safety signs according to the ANSI Z535.2-2011 safety sign is another reason why this sign system is an improvement over the older OSHA-style signs. thereby segmenting typically lengthy instructional information from a hazard alerting or notice sign’s core message. NOTICE is typically the choice of signal word for messages relating to property damage.The fuller amount of content on the typical ANSI Z535.2-2011 standard is signs that use the signal “SAFETY INSTRUCTIONS” or similar words to convey specific safety-related instructions or procedures. ANSI Z535. SAFETY OPERATING PROCEDURES. (e. LOCKOUT PROCEDURE. sanitation.2 safety sign will contain detailed information so the viewer gains an understanding not only of what the hazard is. Exhibit 5. meaning disobeying the sign’s message won’t result in possible personal injury or death. the safety alert symbol is not used since this symbol is only used when potential personal injury is at risk. What is the exact nature of the hazard—are there two sources of power to this electrical panel? How do I properly perform maintenance on this panel? Do I need to perform a lockout/tagout procedure? Do I disconnect the power? What form of PPE should I be wearing? Is there a danger of an arc flash explosion. When lives are on the line. this level of information can be crucial to accident prevention.2-2011 standard is signs that use the signal word “NOTICE. SAFE SHUTDOWN PROCEDURE. More definitive signal words are encouraged with this type of sign.2-2011 Signal word panel for safety instruction signs (Note: More definitive signal words can be used for this type of safety sign) . One interesting point made in the ANSI Z535. EMERGENCY SHUTDOWN INSTRUCTIONS). BOILER SHUTDOWN PROCEDURE. where practical.” These signs display information that is considered important but not hazardrelated. security.

g. the severity of the injury and the probability of it happening. but this section remained practically the same in the 1968 standard which OSHA picked up and used when they wrote their sign regulations in 1971: • • • DANGER signs were only to be used to indicate “immediate” hazards CAUTION signs were only to be used to warn against potential hazards or to caution against unsafe practices SAFETY INSTRUCTION signs were to be used when there was a need for general instructions The problem with OSHA’s continued use of the old standards’ definitions as described above for defining the right sign for an identified hazard. The 1941 standard for Accident Prevention Signs defined the terms which you would use to choose which type of sign went with your safety message. visitors and subcontractors on the different levels of risk as denoted by the signal words on your facility’s safety signs. And that’s a problem. Risk Assessment and ANSI Z535 Safety Sign Design To appreciate the difference between the new and old signage and how risk assessment by today’s standards works only with the newer signs. In the ANSI Z535 standards. and the result is that very little in the way of risk level differentiation occurs. These signs do not use signal words though they may contain a word message to define the type of equipment (e. Fire equipment signs use white letters on a red background and safety equipment signs use white letters on a green background. you will see that their various risk levels (determined by the severity of injury and probability of interaction) allow you to easily choose the right ANSI Z535 signal word. .SAFETY and FIRE EQUIPMENT LOCATION Signs The fourth and final category of safety signs according to the ANSI Z535. it will be wise to train your employees. The “immediacy” of the hazard concept that the 1941 and 1968 standards used is a general term that leans more to the probability of getting hurt if a person ignores the sign. it is useful to know how the old standards worked when it came to differentiating different levels of risk. First Aid Kit). The problem here is that the severity of the injury is not taken into account. you will use DANGER for both “high voltage” signs (because interacting with the high voltage WILL hurt you) and you would use DANGER for “hot surface” signs (because hot surfaces are an “immediate” hazard and touching one WILL also hurt you). If you follow this direction. “immediacy” as shown above. labels and tags. Fire Extinguisher. both are “immediate” hazards. the way the old standards and OSHA defined the use of DANGER signs you use DANGER for all “immediate” hazards. The understanding illustrated below comes from the 1941 standard. You see. Practically every hazard alerting sign becomes a DANGER sign with this way of thinking. In this context. Contrast this to the way the ANSI Z535 standards define the use of signal words as described above. Not just one.2-2011 standard is signs that are used to indicate the direction to or location of safety and fire equipment. is that today’s best practice risk assessment methodologies define risk using two factors. Eyewash. You see. When you use a risk assessment to analyze your hazards. the three clearly defined signal words that you can use to alert people to potential personal injury hazards each have their own level of associated hazard seriousness.

In modern day workplaces. which equates to the fact that they often lack information. information that U. where processes.2-2011 Selection of Signal Word Illustration On Substantial. the .Exhibit 6. equipment and procedures are often more complex. Signs designed to the old standards typically have very short messages. Meaningful Content The new ANSI signs and tags give employers the ability to communicate more substance! Here’s where the old signs are flawed. ANSI Z535. courts have used to define what constitutes an “adequate warning” by today’s standards (ANSI Z535).S.

which.I have to assume that the issue here is not to touch something. WARNING or CAUTION) The nature of the hazard The consequence of interaction with the hazard How to avoid the hazard It’s important to note that the Z535 standards use the word “should” to describe the intent here. What’s the hazard? Heat … how can I get hurt? I’m not sure … . as mentioned before. not serious injury or death. And what’s the seriousness of the risk involved? … it must be really high because it’s a DANGER sign! Now let’s look at the ANSI Z535-style sign. ANSI Z535. That’s not always the case with burn hazards. But most of the time CAUTION is correct.S. Take the “DANGER HOT” sign. interaction with the hot surface most often would result in a minor or moderate injury. as we’ve seen. . You see. it says that hazard alerting safety signs should convey the: • • • • Seriousness of the hazard. the last forty years of U. is done through the use of the right signal word (DANGER.” And. Compare the content they convey to examples of newer ANSI Z535-style signs.ability to convey more substantive safety information is critical. In the safety sign standard. But the standard says in its annex that this is the information that is typically communicated on hazard alerting signs and that many factors must be considered when determining whether or not to omit any of this content. as its foundation.2. case law in the area of products liability and what defines an “adequate warning. it’s not mandated by the Z535 standard for safety signs or safety labels that all of this content needs to appear on a sign. The addition of a symbol on the ANSI Z535-style sign and a more extensive word message. Old (top) and new (bottom) safety sign designs Compare the old-style OSHA signs in Exhibit 7 with the newer ones below them. there’s also been quite a bit of human factors research in the area of warnings over the past couple of decades and that has helped the ANSI Z535 committee in its efforts to define the proper content for safety signs and labels in its standards. this description for the proper content of a safety sign has. meaning this is not a “shall” statement. Typically the signal word CAUTION is used for hot surface signs because even though the potential for a burn may be immediate. Exhibit 7. And this is where the ANSI Z535 safety sign standards excel.

The continued practice by OSHA to only reference the 1967-1968 standards. much like how on-product warnings and products liability became an issue decades ago. tags and labels. formatted in a similar way as the new safety signs. what’s the consequence of interaction with the hazard. has been to create a national uniform system for hazard recognition. The most important aspect of this extended capability to communicate content is that the new ANSI Z535 signage matches up with the information you have gather in your risk assessment. in the field of safety signs. . safer decisions. should help people to make better. OSHA-approved.4 standard for product safety labels. What’s the hazard. and on nearly every type of consumer product. If the safety signs are designed well. the signs to the right compare a “high pressure” safety message. how do we instruct people to avoid the hazard? These are all questions that are defined and answered when doing the hazard analysis portion of a risk assessment…and that is the level of information people today expect to see on product safety labels and facility safety signs. are used on all types of industrial products. And the symbol graphically illustrates what the actual hazard is. Consistency and Uniformity Probably the most convincing reason given to OSHA to change its regulations to incorporate the newer ANSI Z535 safety sign and tag references is this: OSHA’s continued reference of only the old safety sign and tag standards made OSHA (and our workplaces) the outlier in our country where we’ve seen a dramatic and nearly complete adoption of the ANSI Z535. the increased level of information should help people to make wiser. The change by OSHA in September of 2013 to cite the ANSI Z535 standards in their regulations wherever safety signs and tags are mentioned will help this vision for the future of safety communication to take place…. it makes perfect sense to strive to make consistency an objective. The newer ANSI-style facility safety signs are also increasingly being used in public areas where inadequate warnings and premises liability have become an issue. are similar in format to the safety messages we see on the safety signs posted on the walls of the facilities where we work. The goal of the ANSI Z535 standards committee. Standardization in this field of safety communication is meant to eliminate confusion and improve understanding. and finally. which as mentioned before. This is the state-of-the-art for safety signage today and it’s what makes this type of sign significantly more useful than the old OSHA-style sign shown below it. and that’s what they did on September 11. from child car seats to power tools. safer decisions.tells the viewer what the hazard is and what not to do in both words and pictures … which is a lot more than the old sign’s words: “DANGER HOT. furthered a situation that basically prohibited safety professionals from using the new warnings technology and kept workplace owners using signs designed to 1941-era standards. Consistency is one of the goals of standardization and here.2 standard for safety signs.so that the safety messages we see on workplace equipment and on the consumer products we use. ANSI Z535. giving you very specific yet concise information that allows you to understand the hazard and how to avoid it. how probable is the accident. including the machinery found in nearly every workplace. wiser. how probable is the injury. since its formation in the 1980s.” Taking the idea of more substance one step further. standards that. 2013. in the world of best safety practices. The ANSI-style sign has been tailored with specific hazard avoidance information.4 labels. Changing this situation was within OSHA’s power. meaning their symbols and messages are carefully chosen to match the situation and the intended audience. ANSI Z535. The presentation of this paper will examine how ANSI 31000 Risk Management Principles and Guidelines and ANSI 31010 Risk Assessment Techniques define the information needed to discern risk in such a way that it dovetails nicely with the “content items” defined by the now. have been viewed as obsolete for years.

Specifications for Accident Prevention Signs and Tags. ANSI/ASSE/ISO 31010 (Z690. The end result should be improved communication of safetyrelated information leading to significant reductions in risk. and levels of risk severity. 1971. 1941. American Standards Association. 2011. CFR 1910. the new OSHA/ANSI Z535. 2011. ________. ANSI/ASSE/ISO 31000 (Z690.1: Specifications for Industrial Accident Prevention Signs.2: American National Standard for Environmental and Facility Safety Signs. ASA Z35.2 safety signs provide the safety professional with an important tool to better identify hazards. 2013.Conclusion When applied with today’s risk assessment methodologies.2-2011): Risk Management Principles and Guidelines. ________. ________. 2011. hazard avoidance procedures. . Occupational Safety and Health Administration (OSHA). ANSI Z535.145.4: American National Standard for Product Safety Signs and Labels. 2011.3-2011): Risk Assessment Techniques. ANSI Z535. Bibliography American National Standards Institute.