Effective visual communication can help keep\nyour workers safe and your program free of OSHA citations.\n
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Industrial hygienist Sheryl Kuhfeldt has a\nrenewed appreciation for the value of safety signs and labels.\nEarlier this year, the Lyondell Petrochemical Co. facility in\nChannelview, Texas, was involved in a major turnaround project for\none of its olefins plants that took the better part of 70 days.\nBefore and during the turnaround, which involved 1,000 contract\nworkers and some of Lyondell"s 750 employees, the company beefed up\ntraining programs and safety procedures. One of the biggest successes\nin the turnaround, however, came from a new safety labeling\nsystem.
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Lyondell used 4-inch-by-6-inch fluorescent pink\ntags that said "Benzene O.K." to mark process vessels &emdash; 100\nspaces in all &emdash; that had been monitored for benzene and found\nto be safe. That made it easy to identify spaces that could be\nentered, once other confined space entry and permit procedures were\ncompleted. It assured contractors that the vessels were safe to enter\nand prevented duplicate monitoring, which was a problem during a\nprevious turnaround.
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"Communication is always a bigger issue when\nyou have more or new people coming into the facility," said Kuhfeldt,\nwho used pink for benzene because it is common in the environmental\nfield. "We don"t want people guessing about the hazards or if they\nneed monitoring. If there"s no pink tag, there"s no work inside that\nvessel until it is checked."
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According to experts, safety signs, tags and\nlabels should be used to warn people of hazards, remind them of\nprecautions, and instruct them what to do in case of emergency.\nSafety programs that use signs and labels to warn, remind and\ninstruct have a good chance of success.
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"Signs and labels should be part of a larger\neffort to make the workplace safe," said Gary M. Bell, manager of\nproduct safety and environmental compliance for La-Z-Boy Inc., the\nMonroe, Mich., furniture manufacturer. "If you cannot engineer out\nhazardous situations, signs can tell people what the hazard is and\nhow to control it. Training should tell them why."
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Required Reading
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OSHA"s basic requirements for accident\nprevention signs and tags appear in 29 CFR 1910.145 for general\nindustry and 1926.200 for construction. According to OSHA, employers\nshould use signs, tags and labels to "define specific hazards ...\nthat may lead to accidental injury to workers or the public, or both,\nor to property damage."
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The standards provide guidelines for when to\nuse the Danger, Caution, Warning and Biological Hazard signal words\nand recommend a color scheme. Here is the breakdown:
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- DANGER: Red with lettering or symbols in a\n contrasting color to identify that an immediate hazard\n exists.\n \n
- CAUTION: Yellow with black lettering or\n symbols to warn against potential hazards or to caution against\n unsafe practices.\n \n
- WARNING: Orange with lettering or symbols\n in a contrasting color to represent a hazard level between Caution\n and Danger.\n \n
- BIOLOGICAL HAZARD: Fluorescent orange or\n orange-red with lettering or symbols in a contrasting color to\n identify the actual or potential presence of a biological hazard,\n e.g. blood.\n
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Employers can generally decide for themselves\nwhat signal words and signs are appropriate, but common sense can\nmake a difference. For example, posting a "CAUTION: No smoking" sign\nmay be fine for some parts of a plant, but, in an area where\nflammables are stored, signs should read more like "DANGER:\nFlammables Area -- No Smoking."
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For signs to be effective and in compliance,\nthey must "adequately communicate" the hazards, according to Ray\nDonnelly, director of OSHA"s Office of General Industry Compliance\nAssistance. He said illiteracy and non-English-speaking workers put\nan additional "training burden" on employers to ensure that workers\nunderstand hazards and precautions.
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OSHA"s requirements for signs, tags and labels\ndo not end there, however. According to Neal Langerman, Ph.D.,\npresident of Chemical Safety Associates Inc., a San Diego safety and\nhealth consulting firm, a recent computer search revealed 192\nreferences to "signs" in OSHA standards. They are included in\nsubstance-specific health standards as well as the far-reaching\nhazard communication, confined space safety and bloodborne pathogens\nstandards.
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There has been much more enforcement in these\nareas. For example, hazard communication"s requirements for container\nlabeling were cited more than 2,000 times during fiscal 1995. In the\nconfined space standard, the requirement to label permit-required\nspaces or use other means to inform employees is the standard"s\nsecond most-cited provision, according to federal OSHA.
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Langerman said problems with signs and labels\nare also a "serious symptom" of a safety program in trouble. "If you\ndon"t have signs and labels, there are a lot of things you don"t\nhave, and OSHA will see that right away," he said.
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Voluntary Standards
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Where OSHA leaves off in providing guidance,\nvoluntary consensus standards developed through the American National\nStandards Institute (ANSI) pick up. La-Z-Boy"s Bell chairs the ANSI\nZ535 committee, which is responsible for five signs-related\nstandards. They are: Z535.1, which covers color coding; Z535.2, which\ncovers design of industrial safety signs; Z535.3, which covers safety\nsymbols; Z535.4, which covers product safety signs; and Z535.5, which\ncovers the design of tags. A separate chemical industry-sponsored\ncommittee, ANSI Z129, sets the standards for chemical\nlabeling.
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The Z535 standards are being revised and\nupdated, and new standards are due next year. Simplifying color\ncoding guidelines in Z535.1 is one of the most basic proposed\nchanges, according to Bell. He said the new standard will define\nexactly what hue qualifies as "safety red," "safety orange," "safety\nyellow" &emdash; which carry similar usage guidelines to OSHA"s\nrequirements. ANSI Z535.1 will also define and recommend uses\nfor:
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- Safety Green: Identification of safety,\n emergency egress and location of first aid and safety\n equipment.\n \n
- Safety Blue: Identification of basic\n information on signs and bulletin boards.\n
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Safety purple, white, grey, black and brown\nwill also be specified but no applications assigned.
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"We"re not mandating the use of colors," Bell\nexplained. "What we"re saying is that if you use colors as a signal,\nthese are the colors to use."
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Z535.2 will be revised to be compatible with\nthe more stringent signs and labeling requirements in Z535.4. As a\nresult, Bell said, many industrial
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DANGER signs will include an exclamation point\ninside a triangle &emdash; a product labeling provision designed to\nimprove failure-to-warn defenses.
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The committee is also updating Z535.3, the\nsymbols standard. Bell said it will include an "exhaustive test" for\ndetermining if a symbol is recognized by an affected worker\npopulation. "If you can"t test to that level," he said, "we recommend\nusing words and symbols." According to Bell, even such common symbols\nas a cigarette with a red slash through it should be accompanied by\nthe signal word "DANGER" and the words "No Smoking," especially in\nfire-sensitive areas.
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For more information on the ANSI standards,\ncontact Bell at (313)457-2013.
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Labeling at Lyondell
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During routine ethylene and propylene\nproduction at Lyondell, 750 company employees and 450 contract\nworkers are onsite at Channelview. Safety signs, tags and labels are\njust as important then as during turnaround, according to Sheryl\nKuhfeldt.
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Lyondell posts signs throughout the plant to\nremind employees where personal protective equipment is required. In\naddition, a yellow stripe around production areas identifies where\neye protection must be worn.
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The Lyondell Channelview facility is\nimplementing a color coding system for its chemical process lines and\nvessels. According to Kuhfeldt, color-coded areas will be:\nfluorescent orange for pressure safety valves; medium brown for\nhydrogen gas; yellow for nitrogen gas; pink for benzene (at least 10\npercent); grey for acid service; and purple for caustic\nservice.
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"Where there is a recommended color, we use\nit," she said. "Where there isn"t, we pick one, stick with it, and\nmake sure everybody is trained."
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Channelview, a Star site in OSHA"s Voluntary\nProtection Programs, has extensive requirements for chemical\nlabeling. Suppliers are most affected, but Lyondell must label\nchemicals that are transferred from their shipping containers into\nsmaller containers such as oil cans. She said this can help prevent\ninadvertent, dangerous mixtures.
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Kuhfeldt also spearheaded efforts to post\nstreet signs and other directional signs throughout the 800-acre\nsite. These are essential for traffic safety and emergency response,\nshe said.
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Bridging a Language Barrier
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At Alpha Meat Packing Co. Inc., South Gate,\nCalif., a language barrier is the major challenge facing the safety\nsigns and labeling effort. Many of Alpha Meat"s 95 employees speak\nand read only Spanish, and some have trouble reading it.
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As a result, Plant Manager Steve Sayer and\nPresident and CEO Stan Fittinger have invested heavily in Spanish\nclasses for supervisors, English classes for workers and a variety of\nbilingual materials. Everything from the employee manual and\norientation presentations to evacuation procedures and safety signs\nis available in English and Spanish.
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Alpha Meat employees produce case-ready meat\nproducts of lamb, pork and beef. As a result, they use meat and bone\nsaws, razor-sharp 10-inch knives, and grinders and drill presses. The\nplant uses ammonia as a refrigerant.
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Attention to basics summarizes Sayer"s approach\nto protecting workers from these hazards. This includes, he said,\nposting and maintaining "Exit" as well as "Not an Exit" signs (in\nEnglish and Spanish, of course) to reduce confusion during\nemergencies. He focuses on major hazards, such as the dangers of the\nnew electrical room. Red Peligro signs are common in that area, but,\njust to be safe, those doors are also locked.
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Sayer prides himself on his creativity,\nincluding rubber stamps to personalize and update signs, as well as a\nvariety of cartoon-oriented safety posters to remind workers of key\nissues like cut protection, preventing slips and falls, and emergency\nprocedures.
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"We use signs and labels as a reminder and an\nawareness tool," Sayer said. "We"ve found that using symbols and\nwords in people"s native language catch their eyes."
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On the Construction Site
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Safety is a big job on the Northwestern\nMemorial Hospital Redevelopment Project, a Chicago construction site\nthat covers one city block. When completed in early 1999, the site\nwill feature a hospital with an eight-story base and 17-story and\n22-story towers.
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Right now, the site has more than 500 contract\nemployees working for 10 prime contractors and 18 subcontractors.\nPre-certification of contractor safety programs and extensive\nplanning have helped assure safe working conditions, according to\nJohn Tarro, the $580 million project"s director of safety.\n
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Tarro said signs and labels have played an\nimportant role. He noted, for example, that contractors must meet\nrigid requirements for signs and "Danger" tape to protect contract\nworkers from other contractors" overhead work. In addition,\ncontractors must post signs and barricades to prevent access to\nunfinished stairways, temporary decks and restricted areas such as\nwhere insulation is being sprayed.
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Working for the hospital owner of the site,\nTarro requires that all decks, temporary ramps and hoists be labeled\nwith their load capacities. Hoist manufacturers, for example, must\nprovide such information before their equipment is brought on site.\nAccording to Tarro, some 6,000-pound-capacity hoists can fit larger\nloads but cannot lift them safely.
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Tarro said the changing nature of the\nconstruction site makes it difficult to post long-term signs to\nremind employees to wear protective equipment. Thus, training is\ncritical.
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Tarro said several contractors consulted\nemployees and tested equipment before purchasing safety eyewear and\nfall protection. As a result, he reported, they need not be as\nworried about employees not taking the proper precautions.\n
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"We don"t want to overload people," Tarro said.\n"These are good people who know what they"re doing. Signs and labels\nwork where there might be surprises or where people might get\nlethargic."
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Tarro said the site has a general contractor\nthat "spends a lot of our money putting signs up and taking them\ndown." Echoing the sentiments of other experts, Tarro said, "That"s\nfine with me. I think they work."
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SIDEBAR
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DO"S
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Use both symbols and words. Symbols get\npeople"s attention but words are less likely to be\nmisinterpreted.
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Determine if the situation calls for a signal\nword of "Danger," "Warning" or "Caution." An even less serious\n"Notice" can also be used.
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Follow basic color coding\nrecommendations such as red for "Danger," orange for "Warning,"\nyellow for "Caution" and blue for "Notice."
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Make tracking and maintenance a part of\nsomeone"s job -- the safety specialist, safety committee or\nsupervisors/team leaders.
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Post general safety reminders in common areas\nsuch as break rooms, but, for specific hazards, put the message in\nthe immediate area.
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DON"T"S
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Don"t use signs and labels in isolation. Make\nthem part of training and use in conjunction with other information\nsuch as material safety data sheets.
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Don"t expect good signs to overcome\nineffective policies and bad examples set by managers and\nsupervisors.
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Don"t overlook specific signs and\nlabeling requirements in general industry and construction\nstandards.
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Don"t assume workers understand what they"re\nreading, especially in non-English-speaking and low-education\nareas.
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Don"t let hazard signs overstay their\nwelcome. If the hazard is gone, the sign should be, too!
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Sources: Gary M. Bell, La-Z-Boy Inc.; Sheryl\nKuhfeldt, Lyondell Petrochemical Co.; Neal Langerman, Chemical Safety\nAssociates; Steve Sayer, Alpha Meat Packing Co.; and John Tarro,\nNorthwestern Memorial Hospital Redevelopment Project.
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Occupational Hazards, December 1996, page 31