Brian et al,
This is a non-ending topic – hazard markings on equipment
(note that WARNING is a specific key-word so I use the term hazard marking).
It was a detailed discussion at the recent PSES ISPCE meeting
in Anaheim (check the proceedings) . The crux of the problem is that
symbols are not generally understood without a lot of training and
exposure/experience. The behavioral/human factors folks keep pointing this
out and will be called in by the lawyers to condemn your markings if they
don’t contain the needed textual information. The US/ANSI standard properly
implements a defendable approach which includes the words along with the
pictograms.
Do you feel comfortable with all of the symbols in the
cockpit of any imported car? We’re beginning to learn what they mean as
Americans but it still is not always clear and difficult to quickly make
changes while also driving under difficult conditions (how do you do in a
rental car taking it out in a rainstorm after dark).
This is a dilemma for companies that ship products worldwide.
My ongoing recommendation for companies which design for the North American
market and also ship worldwide is to use ANSI markings which include the
pictograms then include each marking in the manual as a picture/illustration
plus include the text in the body of the document in a way that it will be
translated whenever the manual is translated into another language.
Hope this helps.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201
<mailto:[email protected]> [email protected]
From: Brian Gregory [mailto:[email protected]]
Sent: Monday, May 4, 2015 1:25 PM
To: [email protected]
Subject: Re: [PSES] Warning Label: Disconnect from Mains
Hello again, Brian;
It sure does sound to me like you've done your basic diligence; are the
ANSI compliant symbols any different from the JIT compliant symbols? Even
when I was with an NRTL/NB organization, I was often irked by standards
requirements that were not requested or considered useful by actual
customers.
That being said, I've got the feeling that an informed answer would require
a fairly detailed account of "getting dinged in Europe"
Regards,
Brian Gregory
[Colorado]
720-450-4933
---------- Original Message ----------
From: "Kunde, Brian" <[email protected] <mailto:[email protected]>
>
To: [email protected] <mailto:[email protected]>
Subject: Re: [PSES] Warning Label: Disconnect from Mains
Date: Fri, 1 May 2015 18:15:40 +0000
Thanks Doug and Colorado Brian. We liked the look of the new ANSI labels so
we switch over all the warning labels on our products to this style a few
years ago. But now we are getting dinged in Europe and have to replace the
labels with symbols only or with the text in the language of the country we
sold in. This is difficult to do because sometime we ship instruments to our
sales offices in Europe but we don’t know what country it might be sold in
until it is purchased.
Why don’t the EU just decide on one language like the Chinese did? (Those
are fighting words).
We do explain the meaning of our warning symbols in the User’s Manual and
the manuals are translated into different languages depending on the country
it is sold and what our customers want. The users of our type of instruments
are generally well educated (scientists, chemists, engineers, technicians,
etc.) and most of the time they are happy with English only. But when other
languages are requested we try to provide them translated copies fairly
quickly. It’s very costly , too.
Most of our customers send their Users for training at our facility in the
US. Classes are in English Only.
The other Brian
From: dougp01 [mailto:[email protected]]
Sent: Friday, May 01, 2015 1:48 PM
To: [email protected] <mailto:[email protected]>
Subject: Re: [PSES] Warning Label: Disconnect from Mains
I agree with Colorado Brian. It seems that more and more, IEC-based
standards are requiring a full explanation of symbols and warnings in the
user documentation. As it turns out, many clients of mine leave the user
manuals to the very last and they are usually very lacking. Where possible
using symbols only is an economical option.
One exception to using just symbols might be in certain industries where
using an ANSI/IEC compliant labeling system is required. In this case some
verbiage is required. The text should simply describe the problem and how to
avoid it. Nothing more. Proper use of the keywords Danger, Warning, and
Caution are also essential. Since overstating the hazard is not advisable.
All the best, Doug
From: Brian Gregory
Sent: Friday, May 1, 2015 11:31 AM
To: [email protected] <mailto:[email protected]>
Reply To: Brian Gregory
Subject: Re: [PSES] Warning Label: Disconnect from Mains
---------- Original Message ----------
From: "Kunde, Brian" <[email protected] <mailto:[email protected]>
>
Date: Wed, 29 Apr 2015 18:54:17 +0000
Brian, thanks for your input. Can the potential hazard be addresses without
English Text which may be misunderstood by those unfamiliar with the
language? Wouldn’t Symbols Only be better?
[Colorado Brian here] Symbols ON the equipment are sufficient, and often
preferred. John's answer is also correct, that the symbols (even fully
JIT-compliant ones) need explained, in all the appropriate languages (as
defined by ND's), in the supplied documentation. Any additional needed
information can be added at this point by the manufacturer.
So if AHJs, NRTLs, etc. like to see some kind of warning on the outside of
electrical equipment, then won’t the Hazardous Voltage Warning symbol alone
meet this requirement WITHOUT any Text?
As the Machinery Directive states, “Information and warnings on the
machinery should preferably be provided in the form of readily
understandable symbols or pictograms.”
Bingo; warnings on the machinery....
And in the case given in the 61010-1 standards, it doesn’t say that you have
to use Text, but what the warning marking should state. A symbol or symbols
can “state” or have the same meaning as text without the concern of the User
needing to be able to understand the language of the text.
I advise being verbose as possible in the documentation; this can be in
digital format, so needn't incur much additional expense. You, as the
manufacturer, are now officially on record as directing the end user: DO
this, NOT that... etc. Wordy labels can be expensive, and possibly
confusing (esp. when many languages get involved); I was always perfectly
happy with symbols.
CYA, baby....
The Colorado Brian
From: Nyffenegger, Dave [mailto:[email protected]]
Sent: Wednesday, April 29, 2015 10:39 AM
To: Kunde, Brian
Cc: [email protected]
Subject: RE: Warning Label: Disconnect from Mains
Our NRTL asks for the warning “No User Serviceable Parts Inside” when that
is the case but that is relative to products complying with UL/EN 60950-1
and EN 60204-1. Of course that needs to be translated into all appropriate
languages too.
-Dave
From: Kunde, Brian [mailto:[email protected]]
Sent: Wednesday, April 29, 2015 10:21 AM
To: [email protected] <mailto:[email protected]>
Subject: [PSES] Warning Label: Disconnect from Mains
Greetings.
We make laboratory equipment designed to the requirements of the
IEC/EN/UL/CSA 61010-1 Ed. 3 standard.
Most electrical equipment has at least one warning somewhere visible on the
outside of the equipment that states something like, “Disconnect Power
Before Servicing”.
Where does this requirement come from? I see no such requirement in the
61010-1 standard.
The 61010-1 does say, “If the instructions for use state that an OPERATOR is
permitted to gain access, using a TOOL, to a part which
in NORMAL USE may be HAZARDOUS LIVE, there shall be a warning marking which
states that the equipment
must be isolated or disconnected from the HAZARDOUS LIVE voltage before
access.”
However, if our users do not need to gain access inside our equipment, then
I assume such warning is unnecessary.
We used to have a warning label on any tool assessable panel that has
hazardous voltages behind it. However, I do not see this as a requirement in
the 61010-1. In the past, we have had inspectors write us up for not having
such labels on all panels with hazardous voltage behind it. Does this
requirement come from somewhere else? Are the inspectors wrong?
The label we commonly use has the Symbol 12 (hazardous voltage warning) and
English Text that states something like, “Disconnect Power Before
Servicing”. However, when our products are sold into non-English speaking
countries, we sometimes get dinged for the English Text; especially in
French speaking counties. So, if such a label truly is required, can we get
away with only using the Symbol 12?, or can we use a label with a
combination of symbols, such as Symbol 12 and maybe the ISO 3864-2
Disconnect Mains Plug symbol? Is text of some kind required or can we just
use symbols?
Any suggestions or recommendations?
Thanks to all for your input.
The Other Brian
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