Eyes on Compliance: ANSI vs. OSHA Safety Sign Standards
Why you need to consider both standards for safety sign compliance
OSHA and ANSI safety sign standards both aim to protect workers from hazards in the workplace. Because the two sets of standards come from different entities that often work together, it can be tricky to determine how to create compliant safety signs for your facility.
This article will compare and contrast OSHA and ANSI, breakdown what the different safety sign standards are and explain how OSHA and ANSI work together. You’ll also find a handy OSHA/ANSI color-code reference sign for safety signage.
Who is OSHA: Occupational Safety and Health Administration
OSHA is an agency of the United States government that sets and enforces standards for health and safety in American workplaces. OSHA enforces standards with targeted inspection programs as well as responding to work-related safety complaints, catastrophes and fatalities.
Penalties for OSHA non-compliance violations include hefty fines that can max out anywhere from several thousand to hundreds of thousands of dollars for failure to abate and willful or repeated violations. While it is rarely done, misdemeanor criminal charges can also be pursued against employers for severe OSHA violations.
Who is ANSI: American National Standards Institute
The American National Standards Institute (ANSI) is an American non-profit organization that has existed for over 100 years. As an organization, ANSI works to establish voluntary consensus for standards that protect the safety and health of consumers, workers and the environment.
ANSI does not have any legal power to create standards OR enforce them, but instead accredits (i.e. recommends) standards developed by others. ANSI accreditation fosters consensus among professionals in the private and public sector by using due process procedures to ensure unbiased, fair treatment of the standards being evaluated.
How ANSI and OSHA work together
ANSI gets the private and public sector to agree on what safety sign standards are considered “best practices.” However, those standards are completely voluntary, unless OSHA steps in and uses its legal power to enforce them.
OSHA does this in three ways: (1) directly by adoption, (2) directly by reference, (3) indirectly by citing ANSI standards in instances where failure to communicate a hazard resulted in injury, illness or death.
1) OSHA adoption of ANSI safety sign standards
ANSI-accredited best practices for safety signs are the basis of many safety sign standards enforced by OSHA today. In fact, the first published guidelines for safety signs by ANSI (then called the American Standards Association) were used for the basis of OSHA safety sign regulations at its formation.
OSHA may adopt ANSI guidelines as mandatory at any time. For example, in 2002 ANSI began including symbols to enhance safety sign meanings. A 2013 OSHA safety signage ruling integrated ANSI Z535.1-2006(R2011), Z535.2-2011 and Z535.5-2011 into its standards relating to safety signs, giving employers the option to comply with any version of the ANSI Z535-2011 standard.
2) 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 may result in a citation from OSHA.
3) How OSHA can indirectly cite an ANSI standard
While OSHA safety sign regulations are legally mandatory, they sometimes establish general standards for safety without specifying how employers are to meet the standard. Because of this, things can get murky when the OSHA “General Duty Clause” is considered (Section 5(a)(1) of the Occupational Safety and Health Act).
The General Duty Clause states that it’s the employer’s duty to keep the workplace free from recognized hazards. If there is a workplace safety complaint, injury, illness or death, OSHA will investigate whether (1) 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.
Because ANSI safety sign standards are formed by consensus, the mere the existence of an ANSI standard (whether or not OSHA has adopted or referenced it) can be legally interpreted as proof that a hazard is generally recognized. It can also be used to demonstrate that there was an available practical method of hazard communication that the employer chose not to implement.
Why doesn’t OSHA just make it simple and mandate total ANSI compliance?
OSHA must strike a balance between safety and practicality to make sure its safety sign standards can be effectively put into practice by the average employer. ANSI doesn’t have this restriction and considers safety alone when accrediting standards for safety signage.
Even if OSHA cannot not realistically require companies to follow all ANSI safety sign standards, it benefits workers to have an organization like ANSI creating consensus. ANSI standards provide a constantly evolving goal for safety signage best practices that can be consulted by OSHA and implemented by employers at any time.
Required OSHA safety sign types (with referenced ANSI standards)
OSHA safety sign standard 1910.145 regulates safety signs and tags for accident prevention. All three safety sign types listed below are covered in 1910.145 and reference ANSI standards Z53.1-1967 and Z535.1-2006(R2011) for more comprehensive guidelines. Failure to follow ANSI standards for additional safety sign elements may result in an OSHA citation.
Danger safety signs. Hazards that constitute an immediate danger and require special precautions require the use of a Danger Sign to signal the severity of the situation. OSHA regulation 1910.145(d)(2) specifically states that Danger Signs must be in red, black and white.
Caution safety signs are required to warn against potential hazards and/or unsafe practices. OSHA regulation 1910.145(d)(4) specifically requires Caution Signs to have a yellow background, a black header panel with yellow letters and only black letters to be used on the yellow background.
Safety instruction signs. OSHA regulation 1910.145(d)(6) specifies that 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.
Recommended ANSI safety sign types (not required, but best practices)
Warning and notice sign standards are outlined in ANSI Z535.2-2011 (R2017). While not required by OSHA, it is considered best practices to use notice and warning safety signs for better workplace safety communication.
Warning safety 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. For example, germ-prevention safety signs for increased hygiene and social distancing protocols during an outbreak such as COVID-19.
Better safe than cited: safety sign best practices
Consider the following: 1) In order to meet the bare minimum safety sign requirements from OSHA, there are still some ANSI safety sign standards that will 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 cmpliance. As ANSI safety sign standards are more comprehensive, 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.
Additional resources for safety sign compliance
For more help, check out our guide for creating your own effective and compliant safety signs or learn more about specific safety compliance issues, such as the updated Prop 65 rules. You can also use our online design software to quickly and easily create updated safety signage in your facility.
Please note, the contents of this article and related articles on avery.com/industrial are for informational purposes only, are general in nature, and are not intended to and should not be relied upon or construed as a legal opinion or legal advice regarding any specific issue or factual circumstance.