OSHA recently issued a direct final rule incorporating into its general industry and construction standards the latest versions of the American National Standards Institute (“ANSI”) standards for safety signs and tags, ANSI Z535.2-2011 and Z535.5-2011, respectively. The new OSHA rule, which took effect in September 2013, updates OSHA’s 1971 workplace safety sign and tag formats with today’s best practice safety signage designs as defined by the latest ANSI Z535 standards.
OSHA’s rule for signs and tags (29 CFR 1910.145) regulates the form and content of many safety signs and tags, including wording, color, shape, and symbols. The four major types of signs are danger signs (used for the most severe and immediate hazards), caution signs (indicating potential hazards requiring precautions), safety instruction signs (communicating general directions for safety procedures), and biological hazard signs (signifying an actual or potential biohazard that poses a risk to employees). OSHA specifies the information that must appear on each type of sign, where each type of sign must be used, and the format of each sign type.
Tags must contain a signal word (“Danger,” “Caution,” “Biological Hazard,” “BIOHAZARD,” or the biological hazard symbol) and a major message, which states the specific hazard or safety instruction to be conveyed to the employee.
The OSHA signage change provides employers with additional options for meeting the design criteria requirements for safety signage. To avoid imposing additional costs on facility owners, the ANSI Z535-2011 references will appear next to the older ANSI Z35-1968 standards in OSHA’s regulations. Employers will be able to continue to use the same signs and tags they are using now to meet their OSHA compliance obligations, and to use the newer designs to improve workplace safety.
Incorporating the new ANSI standards by reference in the signage rules enables employers who buy and use signs and tags that comply with the ANSI Z35 standards to not receive a de minimis notice from an OSHA inspector. A de minimis notice means the employer implemented a measure different than the one specified in the OSHA rule. Previously, OSHA had allowed the use of the ANSI Z535 standards without a fine or violation, but OSHA inspectors would document their use as a de minimis condition during an inspection.
OSHA requires employers to train workers to understand the information conveyed on safety signs and tags. Safety information and training must be provided to employees in a language that they understand. The ANSI Z535 series of standards addresses concerns about language barriers through its reliance on graphical symbols, clear and concise language, and consistent signal words to identify potential hazards and ways to avoid them.
Download a copy of a white paper about the OSHA revision to its accident prevention signs and tags rule here.
Clarion Safety Systems’ CEO, Geoffrey Peckham, who chairs the ANSI Z535 Committee for Safety Signs and Colors and is chair and delegation head for ANSI to the ISO standards pertaining to safety signs, played a key role in the effort to update OSHA’s consensus standards to better align them with the latest advances in safety sign technology. Over the past four years, OSHA staff, National Electrical Manufacturers Association (NEMA) staff, and Peckham met to discuss the merits of recognizing that the ANSI Z535 series of standards provide an equal or greater level of safety as compared to OSHA’s 1967-68-era safety sign and tag standards references. Side by side comparisons of the old and new standards, human factors research, and materials related to U.S. courts defining “adequate warnings” were all reviewed by OSHA. Based on these evaluations, OSHA decided it made sense to incorporate the newer ANSI Z535 standards into its regulations so that industry could use them to more effectively communicate safety.