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.

The 2013 OSHA Sign Change and Its Effect In the fall of 2013, 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. This seemingly small change is incredibly important to those in charge of safety and risk management systems. The OSHA rule change is significant because it establishes a new, vastly improved bar for visual risk communication. This “raising of the bar” is a direct reflection of our society’s increasing expectation for accurate risk communication. If you choose not to meet this bar, you will more than likely be unnecessarily exposing your company to litigation should an accident occur. 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, 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. Fortunately, the last point on the list above provides a solution: the new risk assessment standards. The process outlined in these standards helps safety and risk professionals to effectively identify hazards, rank them in terms of priority, and then develop and determine risk reduction measures to create a safer product, workplace or public environment.

The Intersection of Risk Assessment and the New OSHA Safety Sign Systems The new OSHA 2013 sign systems take advantage of the latest, best practice warnings technology as defined in the ANSI Z535-2011 safety sign and tag standards. 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, a safer workplace or a safer public environment, the development of new OSHA/ANSI safety sign systems is an important outcome of your risk

assessment process. Improving safety to minimize injuries and deaths is the number one goal. But if an accident does occur, 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. The larger picture here is to understand that OSHA is trying to improve safety communication in the workplace. 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, fewer injuries, and fewer fatalities in nearly every industry. The promise of the new safety sign technology is that when it’s done well, it can improve communication so that people make better decisions about actions that might otherwise get them injured or killed. That’s the critical role safety signs play in the workplace—giving people the information they need to make wise decisions to prevent accidents. Yet up until September 11, 2013, OSHA did not reference the most recent safety sign and tag standards—as a consequence, the warnings technology that has been developed over the past 30 years has not been widely used for safety signs in the American workplace. In fact, just the opposite occurred; OSHA’s non-acceptance of the latest ANSI standards for safety signage actually was a deterrent to their use. The situation was that the way OSHA works, prior to September 2013, if you were an employer that used the newer ANSI Z535 standards for your safety signs and tags, and you had an OSHA inspection, you would be found to be in violation of OSHA regulations. But because you were using the latest versions of the older standards on which OSHA had based its regulations, you would not be subject to a fine, but your documentation would still show, what OSHA calls, a “de minimis” violation. During our discussions, 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 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.

The ANSI Z535.2-2011 Standard’s “System” of Signs It’s important to understand that the ANSI Z535.2 standard applies to all safety signs installed inside facilities, outside facilities, on fences, walls, and posts, in both public and private venues. In short, it applies to practically every safety sign you encounter in workplace and public space environments. It’s also important to understand that the 2011 ANSI Z535.2 standard lays out a systematic approach to communicating safety. The end result of a well-defined ANSI Z535.2 project is not a hodge-podge set of signs that get stuck up on the wall. Instead, use of the ANSI Z535.2 standard requires the people designing the system to consider safety signage as a “system” of visual communication, a “system” that is built in three ways. 1. 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. As a group, these standards are the primary A-level standards used in the United States for communicating safety information in a visual format. The six standards cover the following topics: •

safety colors (ANSI Z535.1)

• • • • •

environmental/facility safety signs (ANSI Z535.2) design and testing criteria for safety symbols (ANSI Z535.3) product safety signs and labels (ANSI Z535.4) temporary tags and barricade tapes (ANSI Z535.5) safety information presented in product manuals and collateral material (ANSI Z535.6)

The theory behind standardizing a system of design components for safety signs is that through the common use of uniform principles for layout, color and content, people will more easily notice, recognize and understand safety messages, distilling them out of the background of the thousands of messages they see on a daily basis. 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. Those responsible for safety must understand how to apply these design principles, looking at them as a system of interwoven components that, taken together, can effectively communicate safety in public and private environments. 2. The ANSI Z535.2 standard establishes clearly defined “categories” of safety signs, each with their own distinct purpose, that when used together, create a system of signage intended to reduce risk and protect people. Once the categorization system is understood, you will see how your plant’s safety signs work in combination with one another to convey safety in a variety of ways. In the end, your safety signs will play a new and more integral role in your facility’s risk reduction and safety training programs. 3. The content displayed on each type or category of ANSI Z535.2 sign has a systematic structure to it. When you understand this structure, 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.

The ANSI Z535.2 Categories of Signs There are four categories of safety signs according to the ANSI Z535.2-2011 standard. Each of these types of signs will be described below.

Hazard Alerting Signs – Signal word selection The best place to start to understand how the ANSI Z535.2 sign system works is to see how the different sign categories are defined and what they look like. The first category of signs is “hazard alerting” signs. These signs use the large colored signal words DANGER, 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, a hazard that could result in personal injury or death. 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). The words in each ANSI Z535 signal word definition, 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. •

DANGER is used to indicate a hazardous situation which, if not avoided, will result in death or serious injury. This signal word is to be limited to the most extreme situations.

•

WARNING is used to indicate a hazardous situation which, if not avoided, could result in death or serious injury.

•

CAUTION is used to indicate a hazardous situation which, if not avoided, could result in minor or moderate injury.

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

Exhibit 2. OSHA-style Z35.1 safety signs (top), 2011 ANSI Z535.2 safety signs (bottom)

Hazard Alerting Signs—Content Selection First, like the signal words, the content components for ANSI Z535.2-2011 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 Z535.4-2011 Standard for Product Safety Signs and Labels. This is important for several reasons. First, for the sake of achieving a national system of hazard recognition, 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. A person should not be confronted with two distinctly different sign systems. Second, 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.S. court decisions that define what constitutes an “adequate” warning. Thus, use of the ANSI Z535.2 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. According to the ANSI Z535.2 and ANSI Z535.4 definitions, the content of a hazard alerting sign identifies the hazard, the level of hazard seriousness, the probable consequence of involvement with the hazard, and how to avoid the hazard. Note that both standards allow for information on consequence, avoidance or type of hazard to be omitted if it can be readily inferred. But both standards also caution the reader to consider many factors when deciding whether to omit any of these content components.

Exhibit 3. Example of a typical ANSI Z535.2 hazard alerting safety sign

The fuller amount of content on the typical ANSI Z535.2-2011 safety sign is another reason why this sign system is an improvement over the older OSHA-style signs. Take the “DANGER—HIGH VOLTAGE” sign. 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, and if so, what level of PPE should I wear before performing maintenance on this panel? A well-crafted ANSI Z535.2 safety sign will contain detailed information so the viewer gains an understanding not only of what the hazard is, but also how to avoid it. When lives are on the line, this level of information can be crucial to accident prevention.

NOTICE Signs The second category of safety signs according to the ANSI Z535.2-2011 standard is signs that use the signal word “NOTICE.” These signs display information that is considered important but not hazardrelated, meaning disobeying the sign’s message won’t result in possible personal injury or death. For these signs, the safety alert symbol is not used since this symbol is only used when potential personal injury is at risk. For environmental/facility signs, NOTICE is typically the choice of signal word for messages relating to property damage, security, sanitation, and housekeeping rules.

Exhibit 4. ANSI Z535.2-2011 Signal word panel for notice safety signs

SAFETY INSTRUCTION Signs The third category of safety signs according to the ANSI Z535.2-2011 standard is signs that use the signal “SAFETY INSTRUCTIONS” or similar words to convey specific safety-related instructions or procedures. More definitive signal words are encouraged with this type of sign, where practical, (e.g., SAFE SHUTDOWN PROCEDURE, SAFETY OPERATING PROCEDURES, BOILER SHUTDOWN PROCEDURE, LOCKOUT PROCEDURE, EMERGENCY SHUTDOWN INSTRUCTIONS). Again, the safety alert symbol is not used with this classification of signal word. One interesting point made in the ANSI Z535.2 standard is that this type of sign can actually appear as a separate panel on another safety sign, thereby segmenting typically lengthy instructional information from a hazard alerting or notice sign’s core message.

Exhibit 5. ANSI Z535.2-2011 Signal word panel for safety instruction signs (Note: More definitive signal words can be used for this type of safety sign)

SAFETY and FIRE EQUIPMENT LOCATION Signs The fourth and final category of safety signs according to the ANSI Z535.2-2011 standard is signs that are used to indicate the direction to or location of safety and fire equipment. These signs do not use signal words though they may contain a word message to define the type of equipment (e.g. Eyewash, Fire Extinguisher, First Aid Kit). Fire equipment signs use white letters on a red background and safety equipment signs use white letters on a green background.

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, it is useful to know how the old standards worked when it came to differentiating different levels of risk. 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. The understanding illustrated below comes from the 1941 standard, 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, is that today’s best practice risk assessment methodologies define risk using two factors; the severity of the injury and the probability of it happening. Not just one, “immediacy” as shown above. 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. And that’s a problem. You see, the way the old standards and OSHA defined the use of DANGER signs you use DANGER for all “immediate” hazards. If you follow this direction, 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). You see, both are “immediate” hazards. The problem here is that the severity of the injury is not taken into account. Practically every hazard alerting sign becomes a DANGER sign with this way of thinking, and the result is that very little in the way of risk level differentiation occurs. Contrast this to the way the ANSI Z535 standards define the use of signal words as described above. In the ANSI Z535 standards, 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. When you use a risk assessment to analyze your hazards, 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. In this context, it will be wise to train your employees, visitors and subcontractors on the different levels of risk as denoted by the signal words on your facility’s safety signs, labels and tags.

Exhibit 6. ANSI Z535.2-2011 Selection of Signal Word Illustration

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

ability to convey more substantive safety information is critical. And this is where the ANSI Z535 safety sign standards excel. In the safety sign standard, ANSI Z535.2, it says that hazard alerting safety signs should convey the: • • • •

Seriousness of the hazard, which, as we’ve seen, is done through the use of the right signal word (DANGER, 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, meaning this is not a “shall” statement, 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. 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. You see, this description for the proper content of a safety sign has, as its foundation, the last forty years of U.S. case law in the area of products liability and what defines an “adequate warning.” And, as mentioned before, 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.

Exhibit 7. Old (top) and new (bottom) safety sign designs Compare the old-style OSHA signs in Exhibit 7 with the newer ones below them. Compare the content they convey to examples of newer ANSI Z535-style signs. Take the “DANGER HOT” sign. What’s the hazard? Heat … how can I get hurt? I’m not sure … .I have to assume that the issue here is not to touch something. 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. Typically the signal word CAUTION is used for hot surface signs because even though the potential for a burn may be immediate, interaction with the hot surface most often would result in a minor or moderate injury, not serious injury or death. That’s not always the case with burn hazards. But most of the time CAUTION is correct. The addition of a symbol on the ANSI Z535-style sign and a more extensive word message,

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.” Taking the idea of more substance one step further, the signs to the right compare a “high pressure” safety message. The ANSI-style sign has been tailored with specific hazard avoidance information, giving you very specific yet concise information that allows you to understand the hazard and how to avoid it. And the symbol graphically illustrates what the actual hazard is. 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. 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. 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, OSHA-approved, ANSI Z535.2 standard for safety signs. What’s the hazard, what’s the consequence of interaction with the hazard, how probable is the accident, how probable is the injury, and finally, 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. If the safety signs are designed well, meaning their symbols and messages are carefully chosen to match the situation and the intended audience, the increased level of information should help people to make wiser, safer decisions.

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 Z535.4 standard for product safety labels. ANSI Z535.4 labels, formatted in a similar way as the new safety signs, are used on all types of industrial products, including the machinery found in nearly every workplace, and on nearly every type of consumer product, from child car seats to power tools. 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, much like how on-product warnings and products liability became an issue decades ago. The continued practice by OSHA to only reference the 1967-1968 standards, standards that, in the world of best safety practices, have been viewed as obsolete for years, 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. Changing this situation was within OSHA’s power, and that’s what they did on September 11, 2013. The goal of the ANSI Z535 standards committee, since its formation in the 1980s, has been to create a national uniform system for hazard recognition. 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….so that the safety messages we see on workplace equipment and on the consumer products we use, are similar in format to the safety messages we see on the safety signs posted on the walls of the facilities where we work. Consistency is one of the goals of standardization and here, in the field of safety signs, tags and labels, it makes perfect sense to strive to make consistency an objective. Standardization in this field of safety communication is meant to eliminate confusion and improve understanding, which as mentioned before, should help people to make better, wiser, safer decisions.

Conclusion When applied with today’s risk assessment methodologies, the new OSHA/ANSI Z535.2 safety signs provide the safety professional with an important tool to better identify hazards, hazard avoidance procedures, and levels of risk severity. The end result should be improved communication of safetyrelated information leading to significant reductions in risk.

Bibliography American National Standards Institute. 2011. ANSI Z535.2: American National Standard for Environmental and Facility Safety Signs. ________. 2011. ANSI Z535.4: American National Standard for Product Safety Signs and Labels. ________. 2011. ANSI/ASSE/ISO 31000 (Z690.2-2011): Risk Management Principles and Guidelines. ________. 2011. ANSI/ASSE/ISO 31010 (Z690.3-2011): Risk Assessment Techniques. American Standards Association. 1941. ASA Z35.1: Specifications for Industrial Accident Prevention Signs. Occupational Safety and Health Administration (OSHA). 1971, 2013. CFR 1910.145, Specifications for Accident Prevention Signs and Tags.