New Standard Causes Manufacturers To Review Product Manuals And Instruction Sheets

Many manufacturers have not changed their product manuals, instruction sheets and other collateral materials to comply with the ANSI standard which recently went into effect. Failure to do so could expose these manufacturers to claims of insufficient warnings in forthcoming product liability cases.

The previously existing ANSI Z535.4 governed on-product safety labels. However, the guidelines in that standard were ill suited for collateral materials. Labels on a product are usually placed precisely where that warning is most likely to have the most relevance, and will utilize colors and symbols to ensure that the message is received in the environment the product will be used. In contrast, collateral materials like manuals and instruction sheets are typically not attached to the product, are much longer, and can contain multiple warnings and notices interspersed with other written information. Longer, more detailed safety information can by conveyed than on a label that is affixed to a product. These differences suggested the need for a standard specifically addressing how safety information should be conveyed in collateral materials.

ANSI Z535.6 was created to provide manufacturers of a broad range of products with a common design direction intended to provide safety information in a visually consistent, orderly manner. Signal words – Danger, Warning, Caution, Notice -- can be chosen to convey the appropriate level of seriousness of the hazard at issue. Those signal words can be placed in a colored box for added emphasis, and some can be accompanied by a safety alert symbol, which is a triangle with an exclamation point in it. (The exclamation when placed inside a yellow triangle is identical to the general warning sign used in the ISO standards used abroad.) While the use of color is not mandatory in collateral materials, when it is used manufacturers should utilize the same safety colors specified in ANSI Z535.1.

The new standard defines four types of safety messages in collateral materials. Supplemental Directives include messages like “Read all product safety labels” and “Keep this manual.” Grouped Safety Messages are presented in a separate section or document with an appropriate title such as “Important Safety Information.” Section Safety Messages apply to a section of a manual or guide which, for example, might avoid unnecessary repetition of information that applies to a whole section. Finally, Embedded Safety Messages are integrated into instructions, procedures or non-safety information. The new standard provides guidelines for the purpose, content, format and location of each type of message within the collateral instructions or manual.

Most American product manufacturers are familiar with the ANSI Z535 set of standards concerning product safety labels. Those standards were initially published by the American National Standards Institute in 1991, and revised in 1998 and 2002. Just last year, a sixth standard - ANSI Z535.6 - was added to that set specifically to address product safety information conveyed in product manuals, user guides, instructions and other collateral materials. Prior to 2006, there had been no standard specifically for warnings and safety information that appeared in operator’s manuals, instruction sheets, and similar materials intended to reach the end user. Without specific guidelines, manufacturers were on their own in drafting instruction books and product manuals, often incorporating some of the precepts mentioned in the other standards in this set which dealt with color codes, safety signs and symbols, product labels and safety tags. That is no longer the case and now detailed directives exist in ANSI Z535.6.

We recommend that manufacturers selling products in this country who have not already done so review and modify their current collateral materials to ensure that they comply with the new ANSI standard. Doing so now and making any changes necessary to bring product manuals and other materials in line could prevent an injury or prove helpful in later lawsuits.

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