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Workplace Solutions

Signs and label clarification

Can you clarify the differences between the previous OSHA sign standard and the recently updated OSHA sign standard that incorporates ANSI Z535?

January 27, 2014

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Responding is Phillip Zee, vice president, merchandising, Accuform Signs, Brooksville, FL.

A recent revision in the OSHA Standard 29 CFR 1910.145 specifications for accident prevention signs and tags formalized that both OSHA- and ANSI Z535-style signs are acceptable.

This was made a final rule on June 13, 2013, and went into effect Sept. 11, 2013. For all their time in existence, ANSI Z535-style signs (pictured below) were never formally acknowledged by OSHA.

Last year, OSHA added to the longstanding 29 CFR 1910.145 specifications for accident prevention signs (and tags) with ANSI Z535.1-2006(R2011), and for consistency amended portions of the Construction Standard with ANSI Z535.1-2006-2011 and ANSI Z535.2-2011. The inclusion of an “or” statement allows employers the choice to continue using, or implement, either sign style.

OSHA determined that ANSI-style signs are at least as protective as OSHA-style signs (referring specifically to signs – or tags – that comply with ANSI Z53.1-1967, Z35.1-1968 and Z35.2-1968).

Previously, although OSHA allowed the use of the ANSI Z535 standards without a fine or violation, OSHA inspectors could document their use as a “de minimis” condition during an inspection. According to OSHA’s Field Operations Manual, a “de minimis” condition occurs when an employer has implemented a measure different than the one specified in a standard, and that has no direct or immediate relationship to safety or health. With the inclusion of ANSI Z535 into the OSHA standard, the “de minimis” condition no longer exists when using the ANSI-style signs.

Further, regarding State Plan States’ rules, which must be at least as effective as the federal rule, it was found that:

“This direct final rule neither reduces employee protection nor alters an employer’s obligations under the existing standards. Under this direct final rule, employers will be able to continue to use the same signs (and tags) they are using currently to meet their compliance obligations under the existing standards’ design-criteria requirements. This direct final rule provides employers with additional options for meeting the design-criteria requirements for signage protection. Therefore, this direct final rule does not alter the substantive protection that employers must provide to employees or impose a new compliance burden on employers.”

The OSHA final rule ultimately gives employers another option to comply with OSHA’s existing signage standards while not increasing the cost of compliance. OSHA determined that this direct final rule imposes no additional costs on any private-sector or public-sector entity. Accordingly, this direct final rule requires no additional expenditures by either public or private employers. And because change-out is unnecessary, OSHA certifies that the rule will not have a significant economic impact on a substantial number of smaller companies who were worried that they were going to have to change all of the signage in their facility.

Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.

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