Marking In-depth

Definitions

As with any subject it is always a good idea to start by defining terms:

Regulatory Requirements

OSHA has established rules throughout 29 CFR 1910 and 1926 regarding the design, application, and use of safety markings in the workplace. At the core of these regulations, employers will discover three major marking regulations:

• 29 CFR 1910.144, Safety Color Code for Marking Physical Hazards;
• 29 CFR 1910.145, Specifications for Accident Prevention Signs and Tags;
• 29 CFR 1926.200, Accident Prevention Signs and Tags; and
• 29 CFR 1926.201, Signaling.

Be aware that §1910.145 calls for signs or symbols when specific hazards are of a nature such that failure to designate them may lead to accidental injury to workers or the public, or both, or to property damage. This is a "catch-all" requirement for posting signs near hazards.

Other agencies, in addition to OSHA, call for various markings, including, but not limited to:

• Food and Drug Administration, 21 CFR;
• Department of Labor, 29 CFR;
• Architectural and Transportation Barriers Compliance Board, 36 CFR;
• Environmental Protection Agency, 40 CFR;
• Office of Federal Contract Compliance Programs, 41 CFR;
• Department of Transportation, 49 CFR and 23 CFR; and
• Other agencies.

Also, several standards organizations recommend markings, including, but not limited to:

• American National Standards Institute (ANSI);
• American Public Works Association (APWA);
• American Society of Agricultural Engineers (ASAE);
• American Society of Mechanical Engineers (ASME);
• Compressed Gas Association (CGA);
• International Institute of Ammonia Refrigeration (IIAR);
• National Fire Protection Association (NFPA);
• Robotics Industries Association (RIA); and
• Other organizations.

What’s more, some of the standards developed by these organizations are not just recommended, but required by OSHA and other agencies. For example, a regulation may refer to a particular ANSI standard. This referral procedure is called “incorporation by reference.” Standards referred to by regulations have the force of law.

Several incorporated standards are very old, and employers may have trouble obtaining copies of these sometimes out-of-print standards. Often the standards organizations have updated their standards since the date of the incorporated standard. However, be careful about following the updated standards, which are not yet incorporated by reference.

According to OSHA, when an employer complies with a more recent consensus standard than the one incorporated by reference, and the employer’s action provides equal or greater employee protection, OSHA may find the employer in violation, but the violation will be considered “de minimis.” Conversely, if the employer’s action does not provide equal or greater employee protection than that which would be provided under the incorporated standard, the conditions shall be appropriately classified as serious, other-than-serious, repeated, or willful and cited along with all other violations noted.

Another point to be aware of regarding standards involves those that are not even incorporated by reference. Standards that are not incorporated by reference may still be used by OSHA as evidence to support a citation under section 5(a)(1) of the Occupational Safety and Health Act (the General Duty Clause) when a particular hazard is not addressed by any regulation or when the OSHA regulation is known to be insufficiently protective. Standards, in essence, prove that a hazard is recognized within industry and by safety experts, and that abatement measures are well-known. However, OSHA claims that consensus standards that are not incorporated by reference do not become an OSHA standard having the force of law.

Lastly, state and local agencies may require further marking beyond federal regulations and organizational standards.

Marking Design and Format

OSHA does not specify much in the way of marking design and format. Section 1910.145 does state that signs must be furnished with rounded or blunt corners and be free from sharp edges, burrs, splinters, or other sharp projections. Also, the ends or heads of bolts or other fastening devices must be located in such a way that they do not constitute a hazard.

Employers may find the following standards helpful in regard to marking size, layout, letter style and size, surface finish, and durability:

Whatever marking designs and formats are used, it is wise to use the most effective and consistent designs and formats. Messages with ineffective marking designs and formats are often ignored, and important messages can be lost in a clutter of varied marking styles.

Marking signal word and message

OSHA will often specify the exact signal word and message required. The signal word panel is the area of a marking containing the signal word. Between OSHA and ANSI, there are at least nine signal words: danger, warning, caution, notice, safety instructions, safety equipment, fire equipment, biohazard, and exit.

The message panel offers the basic words used to convey what you want to say to workers. These messages take many forms: hazard alerts, consequences, prohibitions, actions, and informational. In general, the wording of any message should:

• Be easily read and to the point;
• Contain sufficient, easy-to-understand information;
• Make a positive suggestion, when possible; and
• Be accurate in fact.

ANSI Z35.1-1968, Z35.2-1968, Z535.2-2011, and Z535.5-2011 are adopted by OSHA regulations and cover signal words and messages. Similarly, ANSI Z535.2-2011 (R2017), ANSI Z535.4-2011 (R2017), ANSI Z535.5-2011 (R2017), and ANSI Z535.5-2022 also cover signal words and messages.

Marking language

Many OSHA regulations call for the use of English markings. However, increasingly, workplaces employ more and more employees who read only foreign languages. Employers and government agencies are beginning to realize that there is a language barrier that accounts for greater rates of injury and illness for those who do not understand English. One solution may be to select marking formats that incorporate both English and another primary language. ANSI Z535.2-2011 and ANSI Z535.2-2011 (R2017) recommends either vertical or horizontal formats.

Marking symbols

Symbols and pictorials contribute to a sign’s meaning. Because U.S. workers come from varied backgrounds and cultures, social, reading, and comprehension skills can sometimes differ. Symbols carry universal meaning and they allow for fast communication of hazards and information. Some common hazard symbols include the radiation, biohazard, and no smoking symbols. While these symbols are generally not substituted, employers may develop unique symbols and signs for other hazards.

In fact, OSHA has stated that where it may be difficult to train employees who do not speak English if all hazard information available to them is only in English, employers should use a marking system that incorporates symbols everyone can understand to ensure that non-English speaking employees have the necessary safety and health information about workplace exposures.

OSHA does not require the safety symbol panel on a sign unless a specific regulation mandates one OR, in the case of general industry and shipyards, failure to designate a symbol may lead to accidental injury or property damage. If not required, a symbol panel may still be included, but a symbol panel by itself is not compliant for signs under 1910.145.

Employers may find it helpful to refer to ANSI Z535.3-2011 (R2017) or ANSI Z535.3-2022, American National Standard for Criteria for Safety Symbols.

Marking color

For conveying a message quickly, a marking’s color is just as important as the text. Because certain colors have been associated with specific messages, using those same colors makes it all the more consistent and efficient. Unless specifically stated otherwise, the colors for OSHA signs follow general schemes for general industry and construction:

While OSHA “requires” a particular color scheme for tags for construction, the agency only makes color scheme “recommendations” for general industry. The recommended general industry and required construction color schemes for tags are provided below:

For general industry, OSHA’s Safety Color Code for Marking Physical Hazards Standard, §1910.144, references safety colors yellow and red and what they must identify or designate:

While you will want to follow the provisions and standards listed in the OSHA regulations for general industry and construction, here are the colors recommended in the voluntary consensus standard, ANSI Z535.1-1998, Safety Color Code:

However, note that the 2002 and later editions, including the 2006(R2011), 2017, and 2022 editions, of ANSI Z535.1, no longer have safety color meanings, which appeared in the 1998 and earlier editions.

Marking placement

Some OSHA marking placement requirements include the following:

Other marking placement recommendations include, but are not limited to, the following: