Eyes on Compliance: ANSI vs. OSHA Safety Sign Standards
If you work in an industrial facility, you know that OSHA and ANSI are two terms often connected to safety sign discussions. Especially safety sign standards and compliance. Inexperienced operations and facility managers may even use the two terms interchangeably.
While both ANSI and OSHA safety sign standards aim to protect workers from hazards in the workplace they are completely different in a few key areas. Failing to understand the nuances between ANSI vs. OSHA safety signs increases your chances of an OSHA citation on inspection day.
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What is the American National Standards Institute (ANSI)?
The American National Standards Institute (ANSI) is a non-profit organization dedicated to fostering global competitiveness in US companies and improving the quality of life for Americans. For over 100 years, ANSI has led the way in helping establish voluntary consensus for standards that protect the safety and health of consumers, workers and the environment.
Conversely, the Occupational Sadfety and Health Administration (OSHA) is a US government agency that sets and enforces standards for health and safety. Although ANSI and OSHA are often mentioned together in regard to safety sign compliance, it’s important to understand that ANSI is not a government agency. It does not have the legal power to enforce or set standards for safety signs.
So what does ANSI do? ANSI accredits (i.e. recommends) standards developed by others. ANSI accreditation employs due process procedures to ensure unbiased, fair treatment of the standards being evaluated. This establishes voluntary consensus, which simply means professionals in the private and public sector all agree on the standards, following them is completely voluntary— almost.
How ANSI and OSHA Work Together
While ANSI safety sign standards (and ANSI standards in general) are voluntary, ANSI accreditation often directly influences mandatory OSHA regulations in three critical ways. Firstly, ANSI standards may be adopted by OSHA. Secondly, OSHA may cite specific ANSI standards in an OSHA regulation. Lastly, (and most ambiguously) ANSI standards are considered “generally recognized” by OSHA and can be referred to in instances where failure to communicate a hazard resulted in injury, illness or death.
OSHA Adoption of ANSI Safety Sign Standards
ANSI accreditation of safety sign standards developed over time are the basis of many safety sign standards enforced by OSHA in 2019. In fact, when OSHA was created in 1971, its mandatory Hazard safety sign regulations could be traced through ANSI to before the First World War.
In 1914, the Worker’s Compensation Bureau published the first pamphlet making suggestions regarding safety signs in the workplace. These standards were developed over time, and in 1941 ANSI (then called the American Standards Association) published the first accredited guidelines for safety sign meanings, design and formatting. These in turn were used for the basis of OSHA safety sign regulations at its formation.
OSHA may also adopt ANSI guidelines as mandatory at any time. For example, in 2002 ANSI began including symbols to enhance safety signs meanings. A 2013 OSHA safety signage ruling integrated ANSI Z535.1-2006(R2011), Z535.2-2011 and Z535.5-2011 into it’s standards relating to safety signs, giving employers the option to comply with any version of the ANSI Z535-2011 standard.
When an OSHA Regulation Cites an ANSI Standard
ANSI standards can become mandatory through something called “incorporation by reference.” Which is the term for when a mandatory OSHA regulation cites a voluntary ANSI standard, making it mandatory by proxy. In these cases, failure to follow the ANSI standard will result in a citation from OSHA.
Examples of ANSI standards that are incorporated by reference into OSHA regulations include ANSI Z35.1-1968, which outlines specifications for safety signs to prevent accidents, and ANSI Z535.2-2011, which concerns environmental and facility safety signs.
ANSI vs OSHA Safety Signs: The General Duty Clause Explained
Here is where things murky, and the greatest chance of getting an OSHA safety sign citation occurs. OSHA regulations are law, and as such are always mandatory— that part is pretty clear. However, an OSHA regulation may establish general standards for safety without specifying how employers are to meet the standard.
When this is the case, OSHA allows the employer to decide how to best meet the standard’s goal, but they also expect employers to consider existing consensus standards even if they aren’t legally required. As ANSI standards are an existing consensus (simply by the nature of how ANSI works) failure to follow a voluntary ANSI safety sign standard can be legally interpreted as an employer ignoring an existing consensus standard.
This is specifically outlined in the General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act, which charges employers with the duty to keep the workplace free from recognized hazards. Should a workplace accident occur, OSHA will investigate: 1) whether there was a recognized hazard the employer should have been aware of and 2) whether employees were sufficiently notified of potential hazards via safety signs or some other communication method.
If a safety sign standard for the hazard which caused the accident has been accredited by ANSI, this can legally be used against the employer in terms of OSHA citation. Not to mention other legal actions ranging from civil to criminal charges.
As a voluntary consensus, the existing ANSI standard can be used as proof of a hazard being generally recognized. Additionally, it may be used to prove there was an available practical method of hazard communication the employer chose not to implement.
Why OSHA Doesn’t Mandate Total ANSI Compliance
Taking all the above into consideration, ANSI signage standards are still voluntary, unless specifically cited in an OSHA regulation. If you’re left wondering why OSHA doesn’t simply universally adopt ANSI safety sign standards, you’re not alone.
Attorney Glenn Demby, Esq. explains that OSHA must strike a balance between safety and practicality to ensure its regulations are enforceable (i.e. affordable for all companies). ANSI does not have this restriction and considers safety alone when accrediting standards for safety signage.
However, should something go wrong in your facility, you bear the burden of proving you didn’t violate the General Duty Clause by choosing not to follow ANSI safety sign standards. Mr. Demby illustrates this with a superb example:
“…you don’t have to buy a Rolls-Royce if a Chrysler is almost as safe. But if an accident happens in the Chrysler that wouldn’t have happened in a Rolls, you’d better be prepared to defend your decision from second-guessers. To do that you’ll need documentation of your reasons for thinking the Chrysler offered adequate protection.”
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OSHA and ANSI Color-Code Reference Guide
OSHA safety sign standard 1910.145 regulates safety signs and tags for accident prevention and makes some ANSI safety sign standards enforceable by law under the “incorporated by reference” rule. OSHA establishes three classes of safety signs: Danger, Caution and Instruction. Each class of safety sign has its own set of colors and specifies the nature of instances in which each type of sign should be used.
ANSI Z535.2-2011 (R2017) identifies two additional classes of safety signs: Warning and Notice which are not required by law. However, it is a good idea to use them when applicable in your facility. Incorporating ANSI warning signs and notice signs help you protect workers and cover yourself legally in case of accident.
Danger Safety Signs
When hazards are present that constitute an immediate danger and special precautions are necessary, safety signs that immediately signal the severity of the situation should be used. Under OSHA regulation 1910.145(d)(2) Danger Signs must be in red, black and white, specifically citing ANSI standards Z53.1-1967 and Z535.1-2006(R2011) for further style references.
Caution Safety Signs
OSHA-compliant Caution Signs require a yellow background, a black header panel with yellow letters and only black letters to be used on the yellow background per OSHA regulation 1910.145(d)(4). Caution safety signs are used to warn against potential hazards and/or unsafe practices. Additionally, ANSI Z53.1-1967 and Z535.1-2006(R2011) are to be consulted for further guidelines.
Safety Instruction Signs
OSHA regulation 1910.145(d)(6) Safety Instruction Signs should have a white background, and the panel should be green with white letters. Only black letters should be used on the white background. Like Danger Signs and Caution Signs, additional style guidelines for Safety Instruction Signs are referenced in ANSI ANSI Z53.1-1967 and Z535.1-2006(R2011).
Warning & Notice Safety Signs
Warning and Notice safety sign standards are outlined in ANSI Z535.2-2011 (R2017). Warning signs alert employees to hazardous situations between “danger” and “caution” in severity and should be designed with black letters on an orange background.
Notice safety signs are used for situations not directly related to personal injury, yet contributing to the overall safety and/or health of the employee. Instruction relating to security practices and sanitation measures are good examples of instances in which to use this particular safety sign.
Make Compliance Easy with Custom Safety Signs
Safety signs don’t have to be a pain point in managing compliance for your facility. Avery® Industrial has the tools you need to print your own custom safety signs with no expensive investment or long lead times. Printable signs are easier, more efficient and more flexible to the needs of your facility than ever before.
When you log on to Avery Design & Print online, you have access to hundreds of free printable safety sign designs. Customizable templates for safety signs featuring OSHA/ANSI color schemes, layouts and symbols are at your fingertips whether you’re printing yourself or having Avery print for you. Quickly and easily translate your compliance expertise into custom safety sign designs that look great on inspection day
OSHA/ANSI Safety Sign Inspection Tips
Choose Safety Signs that Function in Your Facility
Avery Surface Safe® Sign Labels are engineered to stand up to industrial work spaces so your safety signs are functional and professionally displayed on inspection day. Equip your facility with custom adhesive safety signs that are rigorously tested to withstand heavy-duty workspaces, protect your workers and set you up for a successful OSHA inspection.
Made from durable polyester materials, Surface Safe Sign Labels resist damage from water, chemicals, abrasions and tears, and are easy to clean. Be prepared for OSHA inspectors with well-maintained professional looking safety signs— even in the toughest, grimiest workspaces.
Build Flexibility into Your Safety Sign System
Avoid citations for safety signs that don’t stay put or keep falling off and be prepared to immediately update safety signage issues to avoid repeat citations. Quality high-performance adhesive signs that remove cleanly and on-demand printing work for you on your time.
Need to replace or update a safety sign for compliance? No problem. Custom safety signs created with Surface Safe Sign Labels stick securely to drywall, painted, metal and glass indoor surfaces, yet remove cleanly. No need to worry about drilling holes for screws, leftover sticky residue or drywall damaged by tape.
On-demand printable safety signs allow you to prepare and make updates quickly and easily whether inspection day is today or two weeks from today. Printing yourself from your own laser or inkjet printer gives you the power to quickly and efficiently correct mistakes or continue preparation right up to the last minute.
Delegate Safety Sign Tasks When Needed
Choosing Avery Industrial means safety signs that are here to work for you when you need them most. WePrint™ custom safety sign printing can deliver as little as one single sheet to your facility in as few as three business days. No high MOQs or long lead times to slow you down on the road to compliance.
Better Safe Than Cited
Consider the following: 1) In order to meet the bare minimum safety sign requirements from OSHA there are some ANSI safety sign standards that will still need to be followed. 2) OSHA’s General Duty Clause opens up the possibility for legal actions regarding not following ANSI standards— even when they’re technically not required by law.
Choosing to implement ANSI safety sign standards throughout your facility (regardless of whether OSHA calls them out by name) is the best way to ensure compliance on inspection day. As ANSI safety signage standards are more comprehensive than OSHA’s, making ANSI guidelines the go-to across the board demonstrates to OSHA you have taken all possible measures to communicate safety hazards in your facility.