As a product manufacturer, your duty to warn in the United States revolves around your ability to successfully inform people of the residual risks left over after you have done your best to design out or guard hazards that are associated with your product’s entire lifecycle.
By “lifecycle,” I mean your product’s shipment, storage, installation, use, service, decommissioning, and disposal. A classic problem, especially with machinery, is that there can be lots of safety information you need to communicate, yet the last thing you want is to apply so many labels on your product that it looks like an Indy 500 racecar. Too many warnings can be as ineffective as too few, as it raises the risk of having all the warnings ignored – too much information can lead to the “crying wolf” situation.
An often overlooked but very effective solution to this issue of information overload is to include the symbol standardized in ISO 7010 for “Refer to manual” (as shown in Figure 1) on a safety label that is applied to your product.
To make this work, use a risk assessment process to determine which safety information belongs on the product and which safety information goes in the manual. Then, a “Read and understand manual” safety label, like the one shown in Figure 2, can be used to effectively tie together the on-product warnings and manual.
By following this process, you’ve essentially built a three-part system for communicating safety. Use of the internationally standardized “Refer to manual” safety symbol tells even non-English reading viewers that they need to read the manual to stay safe from harm. Creating such a system is important because U.S. courts acknowledge that, as a product manufacturer, your two primary vehicles for communicating safety information are your product’s warnings and instructions. The “Read manual” label reinforces this tie-in and puts you in a position of being able to say, “What more could we have done?”
Yet there is a problem with this safety communication system: will your intended audience have ready access to the manual? In the old days, this was an issue because the manual was often lost or stuck in a file drawer. But in the last year or so, a solution has presented itself: the QR (quick response) code. More and more manufacturers are adding a QR code to the “Read manual” labels we supply to them. Again, see Figure 2. By scanning the QR code with a smartphone, the viewer is immediately taken to the product manufacturer’s website where they can choose to either download a manual or read a specific instruction. This puts that critical information directly into the palm of the hand, right there on the spot. With the smartphone market now accounting for more than 40% of the mobile phones in use in the U.S. and growing at double-digit rates each quarter, you now have an even stronger case for saying, “What more could we have done to communicate safety?” When used in conjunction with the specific hazard-related safety labels on your product, your new high-tech “Refer to manual” labels will better help you fulfill your legal duty to warn.
