Occupational Health & Safety

Tue, Jan 6, 2009 Susan Wensel

As a technical writer for manufacturing company, I read your December 2008 Signs and Signals article, "Stop! Don't Ignore the Value of Safety Signs," with great interest. I was a little disappointed with two oversights in the article. The federal government incorporates a great deal of consensus standards by reference into federal regulations. While the author does state that these consensus standards must be followed, she does not make it clear what incorporation by reference is. By incorporating by reference, the federal government has in essence adopted the consensus standard as its own. If the standard uses mandatory language (such as must and shall), these standards are mandatory. If the standard uses discretionary language (such a may and can), these standards are not mandatory and are left to the discretion of the company. My second disappointment is related to the first. Not all the current consensus standards have been incorporated by reference; only those specifically cited have been incorporated. In safety signage, the ANSI standard Z53.1-1967 (per www.osha.gov) has been incorporated; ANSI Z-535.4-2007 has not been incorporated. Otherwise the author did an excellent job providing a brief overview of the subject.