also suggests that explicit information is easier to remember.
Highlights of recent studies are as follows:

In a study to determine how well people comprehend environmental
warnings on household chemical labels, Akerboom and Trommelen (1998)
found that subjects had difficulty determining the relative level of
hazard indicated by the words “toxic” and “harmful,” and did not
know which of these terms was more serious. As a result, the authors
recommend using a more straightforward labeling system with words that
are concrete, specific, and more frequently used.

London (2003) found similar concerns among South African workers who
were surveyed about the comprehensibility of GHS chemical labels. In
hazard statements, workers identified several words that are too
subjective to convey a clear meaning—namely “copious,”
“adequate,” “prolonged,” and “repeated.” London suggests
replacing these terms with more concrete, quantitative terms, or—if
that is not possible—at least using more lay terms such as “lots of
water.”

Hancock et al. (2001) compared how older and younger adults comprehend
explicit and implicit warnings on products such as cleaners, paints, and
polishes. Among other results, the authors found that subjects were
generally more certain about the truth or falsity of explicit
statements, and were less confident in interpreting implicit
information.

Some studies have found that the preference for explicit text applies to
ingredients as well. For example, Edworthy et al. (2004) found that
amateur and professional pesticide users in the UK preferred labels with
explicit hazard explanations (e.g., “dangerous because of X substance
which causes…”) versus statements that simply indicate that the
product “may cause” some effect. Similarly, Heaps and Henley (1999)
found that naming the hazard-causing agent in a chemical product led to
significantly greater believability, although it did not significantly
affect recall or ratings of dangerousness. The authors suggest that the
explicit mention of hazardous ingredients serves a largely symbolic
function (i.e., adding credibility). In a related experiment, Heaps and
Henley tested implicit versus explicit statements of the worst possible
consequences of misusing a chemical product. In this case, explicitness
led to significantly greater believability, perceived dangerousness, and
cued recall among undergraduate subjects (Heaps and Henley, 1999).

Conzola and Wogalter (1998) found that embedding explicit injury
statistics has an effect on label perceptions, too. Warnings with either
numerical statistics or a verbal quantifier (e.g., “a great number of
injuries…”) were recalled better than warnings with no statistics.
Numerical statistics also led to higher ratings of warning importance
and vividness—even if the number was clearly invalid, which suggests
that the key factor is simply having a number. Explicit statistics did
not increase the hazard rating or the likelihood of compliance, however.

Other studies lend statistical support to the notion that explicit text
is more helpful. For example, Braun and Shaver (1999) asked 178 subjects
to rate the perceived hazard of warning signs with many combinations of
variables, including three levels of text explicitness. Explicitness of
text and explicitness of symbols were two variables that accounted for
the largest part of the variability in responses. Specifically, the
authors advise that “warning text should state the severity of
possible injuries,” which will help to justify the need for
precautionary measures.

In a study on baby carriers and feeding bottles, Trommelen (1997) tested
perceptions and comprehension with three warning conditions: no warning,
non-explicit warning (instruction only, such as “keep this plastic
cover away from your child”), and explicit warning (instruction plus
hazard plus consequence, as in “keep this plastic cover away from your
child to avoid suffocation”). Subjects perceived products with
explicit warnings as more hazardous, and when asked to determine whether
an actor in a video was using the product safely or not, the subjects
given explicit warnings were correct 88 percent of the
time—significantly better than those who saw non-explicit warnings.
Explicit warnings were better understood and remembered, although they
did not necessarily increase intent to comply (perhaps because all
groups already had good intentions). Explicit warnings did not take
significantly longer to read than the other conditions.

One frequent concern among manufacturers is that a strong, explicit
warning will scare consumers away. As Dain and Studley (2004) explain in
a legal journal, “[One should] be cognizant of an additional competing
interest held by all manufacturing clients: to actually sell products.
The trick is to create warnings that can help users avoid injuries and
meet an industry standard of care, but do not scare potential users from
wanting to buy the product in the first place.” However, Heaps and
Henley (1999) found that explicit information did not make people less
likely to use a product.

<IP_ADDRESS>.4	Tone

Two of the studies identified in the literature search deal specifically
with the way label text is worded. There are many considerations related
to tone and wording, including the use of active versus passive voice,
the use of personal pronouns, and the use of probabilistic versus
definitive statements. Examples of probabilistic statements include risk
statements that say “…may cause…” or precautionary statements
like “Avoid contact with eyes or skin. Avoid taking internally.” A
definitive alternative to the latter statement would be “Do not get in
eyes or on skin. Do not swallow” (Heaps and Henley, 1999).

In a study of amateur and professional pesticide users in the UK,
Edworthy et al. (2004) adjusted the wording of hazard, instruction, and
consequence statements and then asked subjects questions to gauge their
intent to comply. Personal pronouns (e.g., “You should do this…”)
were found to improve compliance among both amateurs and professionals,
and were generally preferred over instructions that were less personal.

Heaps and Henley (1999) tested recall and user perceptions of labels
with definitive versus probabilistic consequence statements. Definitive
statements led to a significant increase in believability and cued
recall. Tone had no significant effect on likelihood of use, perceived
dangerousness, or perceived importance of following product
instructions. The authors suggest that better recall may have the
greatest impact on actual behavior, though.

<IP_ADDRESS>.5	Bilingual concerns

While bilingual labels are not formally addressed in the GHS, they are
an issue that continues to grow as the U.S. population becomes more
diverse. One recent study provides a number of useful insights on the
best ways to present label text in more than one language.

For his Ph.D. dissertation, Raymond Lim surveyed English- and
Spanish-speakers about their preferences related to bilingual labels
(Lim, 2005). English-speaking participants generally agreed that
bilingual labels are important because some people in the U.S. do not
speak English, and they did not feel overall that bilingual labels
suggest a lower-quality product—debunking one myth that may have led
some manufacturers to resist using bilingual labels. English- and
Spanish-speakers were both asked to rate several configurations of a
pesticide label; variables included the proportion (same size font or
Spanish smaller than English), top/bottom versus side-by-side, and boxes
versus cylinders (to determine the influence of container shape).
Overall, both groups preferred labels with equal font sizes and the two
languages side-by-side, rather than one above the other—perhaps
because it is more natural to scan from left to right. Each group
preferred to have its own language on the left—the primary
position—but this preference was much stronger among English speakers,
suggesting that Spanish speakers did not mind having their text in a
secondary position, as long as it is present. Boxes were preferred over
cylinders, perhaps because a flatter label offers more viewable surface
area, making it easier to see all the content at once.

In the second part of the study, Lim (2005) tested search time when he
varied the location of text, color of text, and whether the text was
signaled by a U.S. or Mexican flag. Not surprisingly, search time was
fastest when only one language was present. Among bilingual designs, the
most effective configuration had both flags, which allowed users to
locate their native language at a glance. When one language was printed
in blue and the other in black, results were mixed. Overall, color and
flags together may have offered too many distracting clues.

<IP_ADDRESS>	Combinations of elements

Key Findings:

Using all of the key label elements together can generally improve
warning performance, compared with labels that only contain a subset of
these elements. However, in some situations, too much information may be
detrimental.

Among the various label elements, some studies suggest that pictorials
have the greatest influence on recall.

Some studies could not be categorized easily in the previous sections
because they tested multiple label elements simultaneously. These
studies are important because they can offer insight into the way
different label elements interact with one another. Highlights of recent
research are described below.

Wogalter et al. (1998a) asked students and community volunteers to rate
the noticeability and hazard level of two existing warning
formats—ANSI Z535.4 product labels and ANSI Z535.2 environmental
signs—as well as possible alternatives. When the same signal word was
used, the ANSI Z535.2 format was generally rated as connoting a greater
hazard than the corresponding Z535.4 sign. Perceived differences in
signal word strength were consistent across all systems. The strongest
alternative was a sign that said DEADLY with a skull icon.

Some studies have examined the relative importance of label elements.
Which items have the greatest impact? To help answer this question,
Braun and Shaver (1999) asked 178 college students to rate the perceived
hazard of several three-part warning signs (signal word, hazard symbol,
and warning text) in which the color, signal word, and explicitness of
text and symbols were varied. Explicitness of text and symbols accounted
for some of the variability in perceived hazard, but color and signal
word did not. In other words, with all other elements being equal, a red
warning was not perceived as significantly stronger than a blue warning,
and a different signal word did not significantly sway the user’s
perceptions.

In a similar study, Meingast (2001) asked students to recall information
from two variations of warning labels: enhanced warnings with color,
signal icons, pictorials, and organized text (following the ANSI Z535.4
standard); and warnings with text only. Among subjects who viewed the
enhanced warnings, the pictorial was the element most frequently
recalled (48 percent of what was recalled). This study also validated
the overall utility of enhanced warnings, finding that the more complete
warnings were more noticeable, led to significantly greater recall, and
made people report a higher likelihood of compliance.

Other findings generally agree that improving all label elements can
improve warning performance. For example, Lehto (1998a) tested
information retrieval from three chemical label formats and found that
subjects generally did best with an “extensive” format that included
pictograms, paragraphs, and horizontal bars indicating the degree of
hazard. Subjects were able to answer more questions correctly when the
label included a range of well-organized content—particularly
information on first aid and spill procedures.

Wogalter et al. (1997a) reported similar results in a test of four
different signs that discouraged people from using an elevator for short
trips. Three signs were text-only, taken from a 1965 study. The fourth
sign had a signal word panel, icons, a pictorial, and more explicit
wording of the desired behavior (i.e., “use the stairs”). Subjects
rated the enhanced sign as more understandable, and a field test found
that it significantly increased compliance over the other options.

Adams et al. (1998) asked a group of students and industrial workers to
react to a variety of warning signs from industrial settings. Signs were
sometimes presented as full versions with signal word, hazard statement,
consequences statement, and instructions statement; other times, they
were presented with one or more of these elements missing. Both groups
recognized the signal word, consequences, and instructions most of the
time they appeared. Overall, though, when asked about the likelihood
that the sign would result in the desired behavior, subjects rated the
full sign as less effective than some of the variations with one or more
elements missing. Here, the authors suggest that instructions may be
less effective when part of a more complete presentation, and thus they
recommend simplicity and clarity, taking into account what the target
audience may already know. The review by Sattler et al. (1997) reached a
similar conclusion:

“Widely encountered guidelines that warnings should comprise four
elements—a standard signal word, statements of the hazard, the
potential consequences, and how to avoid the hazard—are primarily
based on preference studies and may be in error to suggest that all of
this information must be provided in order to elicit the appropriate
response.”

6.2.6	Warning design

<IP_ADDRESS>	General principles

Key Findings:

Many resources are available to advise people on basic principles of
warning design.

In general, labels are more effective when they include enhancements
such as color, borders, and symbols.

Proper font and spacing are important, as is color contrast. Some common
recommendations include black text on white background, a 10-point
sans-serif font, and bold type for the most important items.

The field of warning design is continually evolving. Recently, several
authors have reviewed the literature to develop guidance for warning
designers. Johnson (2006) describes general design concepts for
warnings, while Frascara (2006) provides advice on typography and visual
design. Wogalter et al. (2002) also offer design guidelines, based on a
review of empirical literature.

A few general principles are worth noting because they appear
consistently in the literature. In general, characteristics that enhance
“vividness”—font size, color, spacing, level of specificity, and
symbols—have been found to improve attention, even though some studies
have shown that these characteristics do not have a significant effect
on comprehension or recall (Argo and Main, 2004). In particular, reviews
of the literature suggest enhancing conspicuity through larger and
bolder print, greater color contrast, and highlighting (Parsons et al.,
1999). Wogalter et al. (2006b) provide similar advice, noting that
larger symbols tend to work better than smaller ones, and thick, bold
elements are more legible than thin small details. Researchers also note
that bullets in outline form appear to be preferred over continuous text
(Wogalter et al., 2002).

Rudin-Brown et al. (2004) offer additional design recommendations, based
on a study that gauged the effectiveness of four different label
conditions for child restraint systems to be installed in a vehicle.
Some subjects saw no label, some saw the current manufacturer’s label,
some saw labels that reflected current and proposed Canadian and U.S.
regulations, and some saw “optimal” labels, which were designed
based on a hierarchical behavioral task analysis. The most effective
labels were those with a 10-point sans-serif font, black text on a white
background (for maximum contrast), color-coded arrows, and
illustrations. On some tasks, subjects were more successful with no
label than with the less optimal labels, suggesting that a poorly
designed label can actually interfere with performance.

In an earlier study that was not cited by Sattler et al. (1997),
Laughery et al. (1993) tested warnings on alcoholic beverage containers
to determine which elements influenced noticeability. The authors
manipulated labels by adding a pictorial, adding an alert symbol with a
signal word, making the text red, and/or adding a border around the
warning. The warning was located fastest when all four of these
modifications were present, suggesting that the best designs include a
combination of enhancements.

<IP_ADDRESS>	Color

Key Findings:

Color can make warnings more noticeable and can help organize the
content (i.e., through color coding).

Red is generally perceived to reflect the greatest degree of hazard.
Yellow, orange, and black reflect a lesser degree of hazard, but studies
disagree on the relative ranking among these three colors.

When using color, label designers need to consider other factors such as
color blindness and lighting conditions.

In their review of the literature on warning effectiveness on behavioral
compliance, Kalsher and Williams (2006) summarize several studies that
examined the effects of adding color to warnings. Many of these studies
were cited in Sattler et al. (1997). Overall, Kalsher and Williams
suggest that adding color can influence the noticeability and
effectiveness of warnings—a claim that is generally supported by
studies conducted since 1997.

In a test on the noticeability of warnings, Swindell (1999) measured the
amount of time it took subjects to locate warning text that had been
embedded in medication instructions. Warnings were found significantly
faster when the icon and signal word were presented in either red or
blue, causing the warning to “pop out” from the black text. Colored
text had a greater impact on noticeability than the presence or absence
of an icon. Swindell’s findings echo the results reported by Laughery
et al. (1993), who found that alcoholic beverage labels were located
significantly faster when the text was red instead of black.

Color also can aid in organizing label information. In the child
restraint system study previously described, Rudin-Brown et al. (2004)
found that color-coded warnings improved compliance. In this particular
case, color was used to differentiate between instructions for
rear-facing installation and forward-facing installation, an important
organizational distinction.

In addition to its effects on noticeability and organization, color can
be used to connote a particular meaning. One of the most common uses of
color in warnings involves signal words. The ANSI Z535.4 standard for
product safety signs and labels prescribes the use of color in signal
word panels as follows: DANGER in white letters on red background,
WARNING in black letters on orange background, and CAUTION in black
letters on yellow background (ANSI, 2002c). Many other standards use
similar arrangements. The ANSI Z129.1 standard for chemical labels does
not require colored signal word panels, and the GHS does not either;
however, the GHS does allow for the use of color in signal words,
backgrounds, and other elements as required by the appropriate
regulatory authority. The GHS does prescribe the colors to be used in
the standard pictograms (United Nations, 2005).

Many researchers have investigated the hazard connotations of different
colors. In a review of the literature, Parsons et al. (1999) suggest
that the red-orange-yellow hierarchy used by the ANSI standard generally
matches people’s perceptions of risk, including perceptions among
native Spanish speakers and children as young as 8.

Experimental results since 1997 confirm that red generally connotes the
highest degree of hazard, but among the remaining colors, there is more
disagreement. For example:

Smith-Jackson and Wogalter (2000) asked English-speaking community
members to rate the perceived hazard of ten ANSI safety colors. Red,
yellow, black, and orange were rated the highest (in descending order).
Differences were statistically significant except the difference between
yellow and black.

Wogalter et al. (1997b) asked Spanish speakers to rank the perceived
hazard of ANSI safety colors. Red was ranked highest, followed by
orange, black, and yellow.

Wogalter et al. (1998a) asked undergraduates and community volunteers to
rank various warning components. Red connoted a significantly greater
hazard than other colors, followed by yellow, orange, and black (in that
order). A group of industrial workers ranked the colors from greatest to
least hazard as follows: red, yellow, black, orange.

London (2003) asked workers in four sectors in South Africa to rank the
colors red, yellow, green, and blue in terns of perceived hazard; 95
percent said red represents the greatest hazard, and 58 percent said
yellow is the second greatest hazard.

Banda and Sichilongo (2006) asked workers in Zambia to rate the
perceived hazard of various colors used in chemical labels. Red was
associated with the greatest hazard, followed by yellow.

In a related experiment, Griffith and Leonard (1997) asked college
students to rate colors on nine scales related to three factors:
evaluation, activity, and potency. Red was rated the most
“meaningful” color (i.e., most distinct in meaning from neutral
gray), followed by green, orange, black, white, blue, and yellow.

Griffith and Leonard (1997) also conducted an association test to see
what signal words people associate with specific colors, and vice-versa.
The authors found that DANGER-red and CAUTION-yellow have the strongest
associations; in each case, the color evoked the correct signal word
nearly 80 percent of the time. The pairing of orange with WARNING was
much weaker. Black was most often associated with FATAL and POISON. The
authors theorize that red is a particularly strong warning color because
of its association with stop signs and blood.

Label designers should consider a few other factors when selecting
colors, too. For example, Dain and Studley (2004) advise designers to
consider color-blind or color-deficient users, who may not be able to
distinguish certain color combinations. Dain and Studley also urge
designers to consider environmental conditions—e.g., avoid using a
dark label if it will be read in a dimly lit setting. Other
considerations include fluorescence, glare, and the durability of
colored pigments.

<IP_ADDRESS>	Layout and formatting

Key Findings:

Logical headings convey information more effectively.

Font size and white space are important variables that affect
readability.

Wide, colorful, and jagged borders are generally perceived to attract
attention better than thin or missing borders, but borders may not be
the most important factor in attracting attention overall.

Research on the layout and formatting of warning labels suggests that
the most effective labels are those that use logical headings and
minimize clutter. As Conzola and Wogalter (2001) state, “Visual
warnings that are formatted to be aesthetically pleasing, with plenty of
white space and coherent information groupings (Hartley, 1994), are more
likely to attract and hold attention than warnings without these
features (Vigilante and Wogalter, [1998a]).” Borders may aid in
recognition, too. Wogalter and Vigilante (2006c) summarize a number of
empirical findings, including the fact that white space helps to show
organization. The GHS does not prescribe a particular format or layout
for workplace chemical labels; just the set of elements that must be
included (OSHA, 2006b). Thus, the GHS offers regulatory agencies and/or
manufacturers the flexibility to adopt formatting that they feel is most
appropriate.

In a timed information retrieval test, Lehto (1998a) found that larger
labels decreased the accuracy of information retrieved, perhaps because
they discouraged subjects from consulting other sources (e.g., the SDS)
for information. Subjects did express a preference for labels with
logical headings. Wogalter and Vigilante (2003) measured information
recall and users’ preferences for labels on over-the-counter
medication bottles; variables included font size (4-, 7-, or 10-point),
amount of white space (none, section spacing, or line spacing), and
standard label size versus an extended/pull-out format. Although font
size did not affect recall among younger adults, older subjects
performed significantly better with 7- or 10-point text, versus 4-point.
The amount of white space did not have a substantial effect on knowledge
acquisition, but both groups rated the design with line spacing as the
most readable, followed by the design with spacing between sections. The
extended format helped older adults because it could accommodate larger
print.

In a review of literature on warnings, Parsons et al. (1999) note that
wide, colorful, and jagged borders are generally perceived to be most
effective. In one recent study in this area, Wogalter and Rashid (1998c)
observed how often (and for how long) people looked at warning signs
with different types of borders. Signs with thick red borders or thick
yellow/black diagonal striped borders were noticed more frequently and
examined more thoroughly than signs with a thin black or red border or
with no border at all. In an earlier study on alcoholic beverage
warnings, however, Laughery et al. (1993) found that a border led to
only a marginal decrease in the amount of time it took to locate the
warning on a container. Instead, the factors that seemed to affect
noticeability the most were heading length, the number of lines and
letters per line, and the amount of clutter around the warning (less
clutter is better).

<IP_ADDRESS>	Order

Key Findings:

Presenting a hazard and the corresponding precautions together may
improve understanding.

Warnings related to immediate, specific hazards are generally considered
most important.

The most effective order for warnings may depend on audience
characteristics such as familiarity with the product.

The GHS does not specify the order in which label elements should
appear. However, a few recent studies have found that the order of
presentation can affect comprehension and compliance. For example,
Akerboom and Trommelen (1998) found that combining environmental and
safety information on household chemical labels led to some confusion
during a comprehension exercise; thus, the authors recommend that each
potential hazard be presented together with the corresponding
precautions (and possibly pictograms), so it is clear why each
precaution must be taken. The authors also suggest presenting warning
messages in a “logical” order.

To find out what a “logical” order means, Vigilante and Wogalter
(1997) asked 25 subjects to look at a list of safety warnings for power
tools and place the warnings in order, starting with those that were
most critical. In this experiment, people tended to put specific actions
near the top of the list, particularly warnings that would be most
critical for the initial use of the product (e.g., correct way to
operate the tool, protective equipment, and electric shock hazard).
Warnings related to transport, storage, and maintenance—i.e., later
use of the product—were ranked lower. The preferred order also
corresponded with how another group of subjects ranked the warnings in
terms of importance, injury severity, and likelihood of injury.

As a follow-up to the previous study, Vigilante and Wogalter (1998b)
tested how well people recalled a set of warnings for a power tool,
depending on warning sequence. Males performed best when warnings were
presented with the least obvious hazards first; females did best when
the most obvious hazards were listed first (obviousness was determined
through a pilot study).The second most effective order was by
importance, as defined by Vigilante and Wogalter (1997). This study
suggests that the best ordering may depend on the audience. In this
case, the authors suggest that male users are probably more familiar
with power tools, and therefore only the non-obvious hazards need to be
displayed prominently.

<IP_ADDRESS>	Location

Key Findings:

Warnings tend to be noticed more quickly when they are located in the
upper left portion of an instruction sheet.

Safety precautions are more likely to be followed when they are
incorporated into a product’s directions for use, although warnings
may be better noticed in general if they are included on posters or
signs, rather than on the product.

Cluttered locations make warnings less noticeable.

The location of warning labels can have a great effect on whether they
are noticed or read. Studies on the influence of warning location are
summarized by Kalsher and Williams (2006); many of these studies were
also cited in Sattler et al. (1997). Since 1997, a few additional
studies—summarized below—have examined the location of warnings
within a product label or within the user’s total environment (e.g.,
signs versus instructions versus on-product labels).

Swindell (1999) studied several factors that may affect warning
noticeability, including where the warning appears within a two-column
product instruction sheet. Warnings in the left column were found
significantly faster than warnings on the right, and warnings in the top
or middle of a column were located faster than those at the bottom.
These findings are consistent with the way people read English or
Spanish—left to right, top to bottom. These results build on findings
reported in Laughery et al. (1993) regarding alcoholic beverage
warnings, which were significantly more noticeable when located on the
front of the container (as opposed to the sides or back) and when the
text was printed horizontally. Vertical text was significantly easier to
find when it read “up” rather than “down,” and overall label
clutter decreased noticeability—confirming a commonly held belief.

In a study of amateur and professional pesticide users in the UK,
Edworthy et al. (2004) found that both groups of users complied with
safety precautions most often when these warnings were included in the
directions for use. This location was found to be more effective than
warnings in a “precautions” section, a “statutory conditions”
section, or an additional leaflet. With professional users, compliance
was also higher when a supplemental directive was present, pointing them
to where safety instructions were located.

Argo and Main (2004) analyzed results from 48 warning studies published
between 1975 and 2001. Among other things, the authors found that
warnings are more effective in attracting attention when they are on
posters, signs, and/or advertisements, as opposed to on the product
itself. It is not clear whether this finding extends to situations
involving occupational chemical use, however. For example, in a
chemistry lab task, Wogalter et al. (1998b) found that subjects were
more likely to use PPE when a safety warning was included in an
instruction sheet, rather than a sign posted on the wall.

6.2.7	Receiver characteristics

Some of the factors that influence the effectiveness of warnings have to
do not with the warning itself, but with the audience. These audience
variables—or receiver characteristics—include gender, age,
familiarity with the product, and the cost of compliance. Although
receiver characteristics are out of the label designer’s control, they
are still worth considering because it may be possible to adapt the
label design to better accommodate the needs and characteristics of a
particular group of users. Recent research on receiver
characteristics—and how they may impact the way we think about label
design—are summarized in the sections that follow.

<IP_ADDRESS>	Gender

Key Findings:

Research has found very few gender differences related to warning
comprehension or compliance.

Warning designers probably do not need to consider gender factors unless
they are creating labels for gender-specific products.

Many studies on warning labels have looked at how gender might have
influenced the results. Overall, as Parsons et al. (1999) explain,
“Most research has failed to find (or report) gender differences on
warning related measures.” A review by Wogalter et al. (2002)
reiterates this assertion, noting that gender factors tend to be
relevant only when the warning is for gender-specific products.

The search for studies from 1997 and later turned up two examples of
gender differences in warning perception. In a survey of 1,500 adults
and children in the UK, Hellier et al. (2000a) asked participants to
rate three signal words on a hazard scale from 1 to 10. Males and
females gave the same order (DANGER, WARNING, CAUTION), but for all
three words, females gave higher hazard ratings than males. The other
example of gender difference comes from Vigilante and Wogalter (1998b),
who found that when multiple warnings are present on a safety label, the
order that optimizes comprehension varies by gender. Males recalled more
information when hazards were ordered from least to most obvious, while
females performed better when the most obvious hazards were listed
first. The authors surmise that this effect may be due more to
familiarity than to gender, as male subjects were more likely to be
familiar with the product (a power tool) and would thus be more engaged
by a presentation that starts with the least recognizable hazards.

<IP_ADDRESS>	Age

Key Findings:

In general, children and adults have similar perceptions of the relative
hazard conveyed by colors and signal words.

Most studies have found that younger adults comprehend warning text and
symbols better than older adults do.

Many cognitive functions decline with age. Understanding these
age-related declines in ability can help warning designers create labels
that are better understood by older adults.

In a study that asked 1,500 adults and children in the UK to rate the
degree of hazard implied by the signal words DANGER, WARNING, and
CAUTION, Hellier et al. (2000a) found strong similarities among the
rankings from children and adults. When the data are broken down,
smaller age ranges demonstrate the same pattern as well, with the
exception of 15-to-24-year-olds, who showed more variability—perhaps,
as the authors surmise, because this age group has been confused or
desensitized by so many different warnings regarding drugs, alcohol,
safe sex, etc. Overall, though, the study shows that adults and children
agree on hazard associations. Other studies have shown that adults and
children have similar hazard perceptions for warning colors, too
(Parsons et al., 1999).

Far more research, however, has been devoted to differences in warning
effectiveness between younger adults and older adults. The effects of
aging are of particular concern as the American workforce—i.e., those
who the HCS is designed to protect—becomes older.

Studies generally show that label comprehension declines with age. For
example, Sansgiry et al. (1997) tested how well consumers process
information on over-the-counter drug labels, and found that older adults
scored significantly lower than younger adults on a comprehension test.
In another test on medication instructions, Sojourner and Wogalter
(1998) found that older adults (mean age 68.0) recalled only 50 percent
as much information as undergraduates did. Younger adults (mean age
33.6) performed better than older adults but not as well as
undergraduates. Wogalter and Vigilante (2003) found that younger adults
acquired information from a medication bottle significantly better than
older adults no matter what label format was used. Older people also
took longer to answer the comprehension questionnaire.

Schroeder et al. (2001) studied age effects in understanding 40 ANSI
safety symbols. For all four types of symbols (mandatory action,
prohibitory action, information, and hazard alerting), younger adults
had significantly higher average comprehension than older adults. In a
similar study, Hancock et al. (1999) tested 12 safety symbols and
discovered that older adults had poorer comprehension for the alert,
hand protection, no lit matches, no people, flammable, and slip symbols.
However, older adults still said that symbols were helpful in
understanding warnings.

In another study on symbols, Lesch (2004) examined how well younger (age
18-35) and older (age 50-65) individuals comprehended warning symbols
before and after training. Of 31 symbols, 15 had significant age-related
differences in comprehension before training—in all cases, older
adults understood less. Younger people were not more familiar with these
symbols, so the author suggests that the difference is more likely due
to how effectively the symbols cue other knowledge. These results build
upon previous studies which found that young people comprehended
chemical and physical safety symbols better than older adults both
before and after training (Lesch, 2002, 2003).

Among recent studies, at least one did not find a decline in
comprehension with age. To compare how older and younger adults
comprehend explicit and implicit information in consumer product
warnings, Hancock et al. (2001) asked two groups of subjects to read
warnings for household chemical products, then rate the truth or falsity
of test statements. Older and younger adults had similar comprehension
levels overall. One noticeable difference was that older people tended
to rate false statements as more “false” than younger people did,
perhaps because their greater life experience made them more certain
about their answer.

Although several studies have shown reduced label comprehension among
older adults, there may be some room for improvement through label
designs that account for what science has learned about the aging
process. Psychology literature provides a large and growing list of ways
in which cognitive processes change with age—changes that affect every
one of the steps in processing warnings (notice, encode, comprehend, and
comply) (Rousseau et al., 1998). Rousseau et al. (1998) provide the
following list of age effects from the literature, along with specific
recommendations for label designers:

Older adults have more difficulty discriminating between colors,
especially those with short wavelengths (green, blue, and violet).
Labels should avoid using these colors to differentiate items.

Older adults have more difficulty discriminating between contrasting
patterns or areas of darkness. Labels should offer high contrast between
text and background.

Older adults have increased susceptibility to glare. Avoid placing
warnings on surfaces that produce glare.

Older adults have reduced visual acuity (ability to resolve small
details). Label designers should use 12- or 14-point type with a
sans-serif, medium to bold font, and should avoid text in all capital
letters.

Older adults have more difficulty selecting relevant information from a
visual array, as a person’s useful field of view (UFOV) declines
rapidly with age. Designers should eliminate clutter, place important
information near the focal point, and use a 1:100 ratio of letter size
to distance for signs.

Older adults have reduced working memory, which can be a particular
problem if a warning requires multiple steps to comply safely. Warning
designers should provide cues to aid memory—for example, by putting
warning information on the product to cue recall.

Older adults have a decreased ability to process complicated text.
Labels should use simple, explicit sentences.

Older adults show a decline in prospective memory (i.e., remembering to
perform actions in the future). Warnings should be available when
needed.

Empirically, older adults have difficulty comprehending the information
in symbols, although the reasons why are unclear. This effect may be
related to working memory. Symbol designers should include older adults
in pilot testing.

Empirical evidence suggests that many of the age-related cognitive
factors listed by Rousseau et al. (1998) do indeed affect older
adults’ performance in reading and complying with warning labels. For
example, Parsons et al. (1999) reviewed the literature and found that
older adults may have difficulty establishing links between symbols, and
they are strongly affected by legibility. Wogalter and Vigilante (2003)
found that older adults recalled significantly more information from a
drug label when the font was 7- or 10-point, rather than 4-point. After
finding that older adults had more trouble than younger adults
comprehending abstract warning symbols, Lesch (2004) suggests that older
adults may have a greater need to trigger context-specific knowledge,
which they are more likely to have for symbols that are less abstract.

<IP_ADDRESS>	Product familiarity

Key Findings:

Familiarity with a product can make users more familiar with the proper
precautions, and therefore more likely to comply with warnings. In other
cases, however, familiarity might have the opposite effect.

Familiarity with a label might make users less likely to read it
carefully.

Familiarity with a particular type of container can affect hazard
perceptions.

In some cases, familiarity with a product may increase compliance. In
other cases, however, familiarity may make a user less likely to read
instructions or safety labels, or more comfortable using the product
without taking the recommended precautions. Kalsher and Williams (2006)
summarize several pre-1997 studies on the effects of product familiarity
on compliance. Three more recent studies shed further light on the
relationship between warning labels and familiarity.

After conducting a meta-analysis of 48 warning studies to date, Argo and
Main (2004) conclude that familiarity has a positive effect on
compliance with safety instructions. When users have previously
interacted with a product, they suggest, those users have had more
opportunity to learn appropriate safety behaviors. Edworthy et al.
(2004) found a similar effect among pesticide users in the UK. Overall,
professional users complied with 60 percent of safety directives,
compared with 34 percent for amateurs. The authors theorize that people
who use the product every day may be more likely to use safe procedures
because they are subject to regulatory requirements and they may be more
concerned with their legal liability, personal safety, and job security.

Edworthy et al. (2004) draw a distinction between familiarity with the
product and familiarity with the label, however. In the pesticide user
study described above, compliance was lowest when safety information
appeared in the part of the label where people would most expect to find
it. Compliance was greatest when that information was moved to the
directions for use. The authors suggest that while product familiarity
increases safety knowledge, familiarity with the label makes people less
likely to read it carefully—a case in which “familiarity breeds
contempt.”

In a somewhat related study, Meingast (2001) asked subjects to recall
the contents of safety labels which were manipulated by placing them on
different types of containers, among other things. Container type did
not affect recall, but it did affect perceptions of hazard
severity—perhaps because of users’ familiarity with other products
in these types of containers (e.g., boxes versus bottles). Argo and Main
(2004) agree that product type can affect judgments.

<IP_ADDRESS>	Cost of compliance

Key Findings:

Cost of compliance is widely recognized as a factor that affects
behavioral compliance with warning labels. Important considerations
include the amount of time, money, and effort required to comply with an
instruction.

Another factor that can affect compliance with safety instructions is
the cost of compliance. Kalsher and Williams (2006) explain this concept
well:

“Costs associated with compliance include expenditures of time, money,
or effort. When people believe that following the proscribed behavior
will take too long, cause too much discomfort, or is too expensive, they
will be less likely to heed the warning.”

Kalsher and Williams (2006) provide a useful table of studies on cost of
compliance, while Argo and Main’s (2004) meta-analysis of previous
studies agrees that cost of compliance can have a significant effect on
behavior. However, a search of the literature published since 1997
produced few recent studies on cost of compliance. In one study that was
available, Chunin (2002) conducted a safety attitude survey among 91
workers and 13 foremen in chemical factories in Thailand, and found that
likelihood of complying with warning signs (e.g., instructions to wear
PPE) depended on perceived cost of compliance. A follow-up survey found
that rewards and punishment also had a significant effect on compliance
with safety signs.

6.2.8	Related topics

Given the relatively robust body of literature on visual warnings, many
recent studies have ventured into the newer territory of multi-modal
warnings (i.e., warnings that appeal to multiple senses). Because the
HCS and GHS pertain to visual warnings, we will not attempt to describe
the literature on multi-modal warnings in great detail here. It may be
worth noting some key findings, however.

Kalsher et al. (1997) examined the extent to which subjects complied
with safety warnings on a bottle of glue. One condition involved a
raised border around the safety warning, which was designed to attract
attention through vision and touch. The raised border led to higher
compliance than a safety label with no raised border, but the difference
was statistically insignificant. When asked their opinions, 94 percent
of subjects said the label with the raised border was most effective at
conveying information, and 55 percent thought it had the most consumer
appeal, compared with the nonraised border or the control product (no
warning).

Cohen et al. (2006) describe the latest research on interactive
warnings, audio warnings, and warnings that involve the other senses
(tactile, olfactory, and gustatory). For example, the authors note that
raised borders can help visually impaired users recognize a potential
hazard.

Other studies have examined the role of stress in warning compliance.
Research suggests that in general, compliance with precautionary
measures is reduced when the user is under pressure to complete a task
in a limited amount of time. For example, in a study that asked
participants to measure and mix chemicals in a laboratory setting,
Wogalter et al. (1998b) found that subjects given a 5 minute time limit
were significantly less likely to follow safety instructions (wearing
PPE) than subjects who were given no time limit to complete the task.
Wogalter et al. also tested another form of stress: social monitoring.
In this study, placing an evaluator with a clipboard next to the
participant (i.e., higher social stress) led to a small but
statistically non-significant increase in warning compliance.

6.2.9	Research needs

In addition to reporting findings, the documents obtained through this
literature search contain a number of recommendations for future
research. The list below is by no means complete, but instead represents
a partial list of key suggestions:

Rousseau et al. (1998) suggest assessing the costs and benefits of
standardization, which may facilitate visual search but cause
habituation to the warning message. In particular, Drake et al. (1998)
suggest a need for more information about habituation to signal words.
This area of research will be increasingly important as more regulatory
bodies transition to the international standard set of signal words.

Fagotto and Fung (2002) recommend that after introducing harmonized
labels and SDSs, OSHA should test their comprehensibility and impact in
changing workers’ behavior. If the new materials are not effective,
stronger emphasis on training may be needed.

Based on a review of warnings research as of 1999, Parsons et al. (1999)
suggest additional research in the following areas:

In general, conduct more measurement of actual behavioral compliance.

For cases where actual behavior cannot be measured (e.g., because it
would put the subject in danger), confirm the utility of alternative
measures.

Consider virtual reality experiments to simulate actual behavior.

Consider effects of state (alcohol, drugs, fatigue, stress) and
personality factors on warning effectiveness.

Involve a broader range of participants, in terms of both age and
culture.

Based on another literature review, Rogers et al. (2000) note that there
is little empirical evidence to date to evaluate potentially important
variables such as attention fatigue, working memory, vision, motivation,
reading comprehension ability, intelligence, technical knowledge,
ability to comply, decision making, physical quality of labels (e.g.,
degradation), legibility, and credibility of source. In addition, more
research is needed on the relative importance of different variables, as
well as interactions among variables.

7.	Training

7.1	Background

In the current HCS, OSHA requires employers to provide employees with
“effective information and training” on hazardous chemicals (OSHA,
1994). The HCS describes what elements must be addressed, but does not
tell employers exactly how to conduct the training. OSHA’s Training
Institute has prepared some voluntary guidelines that are applicable to
training in general (OSHA, 1998).

The GHS does not prescribe specific requirements for hazard
communication training. However, the GHS does note that worker training
is an integral part of the hazard communication, and it suggests that
training requirements be “appropriate for and commensurate with the
nature of the work or exposure” (United Nations, 2005, § 1.4.9). As
the next section explains, research on hazard communication continues to
support the role of training in promoting worker health and safety.
Consensus standards support this view as well. For example, Annex A of
ANSI Z535.2 recommends training on the meaning of standard safety
symbols and signal words; ANSI Z535.4 contains similar guidance.
Countries in Europe have adopted European Commission Directive 98/24/EC,
which includes general provisions for training workers who deal with
hazardous chemicals (European Commission, 1998).

For more specific guidance, employers can consult other resources. For
example, the American Society of Safety Engineers (ASSE) has developed
ANSI/ASSE Z490.1, the American National Standard on Criteria for
Accepted Practices in Safety, Health, and Environmental Training (ASSE,
2001). ANSI/ASSE Z490.1 provides requirements and guidance in the
following areas:

Program administration and management

Program development (e.g., course design)

Delivery (e.g., trainer criteria and the training environment)

Evaluation

General systems and procedures

7.2	State of the science

7.2.1	Literature reviews

Sattler et al. (1997) reviewed health and safety training literature
published up to 1997. Among other things, the studies reviewed in that
document included successful training intervention studies and research
on the many factors that can affect training performance, such as the
degree of support from plant management. Sattler et al. also suggest
that literacy and language issues require more investigation.

Since 1997, a few additional reviews of the training literature have
been published. In 1998, NIOSH published an update to a previous review
on occupational health and safety training, adding studies conducted
through 1996 (Cohen and Colligan, 1998). Bouchard (2007) reviewed nine
training intervention studies conducted between 1983 and 2005; however,
most of these studies were already cited by Sattler et al. (1997).

In a related study, Fung et al. (2004) reviewed the literature to
determine the effectiveness of several “transparency systems,”
including OSHA’s HCS. Overall, the authors rate the HCS as moderately
effective, meaning that “The transparency system has changed behavior
of a substantial portion of users and disclosers in the intended
direction but has also left gaps in behavior change and/or generated
unintended consequences.” Fung et al. note that improved access to
information has helped some employers switch to safer alternatives, but
cite studies showing that this information is not well embedded in
employees’ decision-making, and that SDSs are of varying quality and
are often too complex. As described previously in the section on SDSs,
Fung et al. sum up their assessment as follows:

“Overall, the hazard communication system appears to function better
as a tool to exchange information among chemical producers and chemical
users than as a device to help employees to protect themselves at work,
avoid dangerous workplaces, or demand higher pay in light of increased
risk.”

7.2.2	The need for training

Key Findings:

Training will continue to be a need under the GHS, considering that even
some common label elements may not be widely understood.

Worker surveys confirm that training can lead to safer practices.

Many of the recent studies on SDSs and warning labels have included some
type of training component—for example, testing comprehension of
pictograms both before and after a brief training session. Nearly all of
these studies demonstrate some type of improvement due to training;
indeed, several authors specifically recommend training as a tool to
increase comprehension and compliance.

Training will continue to be a need under the GHS. For example, in a
test of GHS labels in Zambia, Banda and Sichilongo (2006) found that
“…correct responses to label elements were not a result of social
class and/or age but appeared to be influenced by extent of duration of
exposure either through specialized training or acquaintance.” In a
similar study in South Africa, Dowse and Ehlers (2003) found that some
subjects were unfamiliar with fundamental pictogram elements like the
prohibition (slash) symbol—particularly less educated users. Some
subjects exhibited critical confusion: that is, interpreting the
opposite of the intended meaning. As the authors explain, these results
show the importance of basic training to make people more familiar with
safety symbols.

Worker surveys have illustrated the importance of training, too. For
example, in a survey of 180 emergency responders who were trained at a
hazardous materials worker training center, Weidner et al. (1998) found
that 42 percent of respondents had experienced at least one incident
that would have resulted in injury or death without training.

7.2.3	Training intervention studies

Key Findings:

Overall, training has been shown to improve safety attitudes and safety
behavior in the workplace.

In studies on symbol comprehension, training generally leads to greater
understanding. A simple explanation of each symbol is just as effective
as a longer explanation.

Overall, a wide range of studies have shown that training is effective
at improving worker safety and health. NIOSH sums up these findings in
its 1998 literature review, stating, “…evidence that OS&H training
can reduce risks from workplace hazards remains strong. Indeed, the
issue is not so much whether OS&H training is worthwhile but what
factors both within and beyond the training process can produce the
greatest possible impact” (Cohen and Colligan, 1998). The NIOSH review
also provides examples showing the success of OSHA’s voluntary
training guidelines in action. In an appendix, the authors provide
results from training intervention studies, essentially representing the
state of the science as of 1998 (Cohen and Colligan, 1998). Many of
these studies were already described by Sattler et al. (1997).

As Cohen and Colligan (1998) note, the effectiveness of training depends
on many factors, including size of group, length/frequency of training,
training mode, transfer, motivation, trainer qualifications, management
role (apparent benefits from using supervisors or foremen as trainers),
etc. Unfortunately, the literature published in the last decade does not
contain much more information about these factors. There have been some
additional studies showing the effectiveness of training intervention,
however.

Tan-Wilhelm et al. (2000) compared attitudes and behavior among workers
at two plants that handle beryllium. At the intervention plant, a
presentation on beryllium hazards was given to all employees, along with
two information bulletins plus reminder stickers and posters. These
materials recommended that employees reduce exposure by washing their
hands, changing clothes before leaving the plant, and vacuuming their
cars regularly. The control plant did not receive these materials.
Although workers at both plants had high levels of perceived severity,
the intervention subjects reported stronger perceptions of
susceptibility, higher self-efficacy (believing they can take steps to
reduce exposures), and higher response efficacy (believing these steps
will be effective). They also had more positive attitudes toward safety
measures and stronger intentions to engage in safety behaviors. One
month after training, workers at the intervention plant reported
significantly higher rates of hand-washing and vacuuming cars, compared
with the control plant. These self-reported results were supported by a
significant increase in hand soap use. Workers reported that the
plant-wide presentations were the most influential part of the training.

Weidner et al. (1998) surveyed 180 emergency responders who attended a
hazardous materials worker training center funded by the National
Institute of Environmental Health Sciences (NIEHS). After training, at
least 90 percent of trainees felt confident in their ability to recall
specific critical concepts in a crisis. Respondents rated technical
topics (hazard recognition, decontamination, protective equipment) as
the most critical areas for training. Workers recommended that training
be extensive and uniform across jurisdictions, emphasize technical
aspects of health and safety, and include demonstration and hands-on
techniques. The survey results also suggest that integrated
organizational support is critical for implementing health and safety
practices.

Following a review of nine training intervention studies, Bouchard
(2007) identified three main problems with current hazard communication
training:

The lack of learner involvement to improve hazard communication.

The lack of employer assessment of employee understanding of training
provided.

The lack of studies assessing retention of the material taught and its
application at the worksite.

In addition to the studies described above, there have been other recent
investigations which, while not truly training intervention studies,
nonetheless provide useful observations about the role of training in
improving warning comprehension and compliance.

In one such study, Wogalter et al. (1997c) tested how well undergraduate
subjects comprehended a set of 40 pharmaceutical and industrial safety
pictorials before and after training. Training led to a significant
increase in pictorial comprehension, even up to 6 months later. The
improvement was greatest for the most complex symbols. Training was
equally effective whether the subject was given a simple printed label
(e.g., “Danger, cancer-causing substance”) or a label with
additional explanatory text.

Lesch (2002, 2003) conducted a similar study, testing how well workers
recognized a set of 31 chemical and physical safety symbols before and
after training. Training significantly improved comprehension, which
remained higher up to 8 weeks later. Younger and older adults showed
similar amounts of improvement due to training, although younger adults
performed better overall both before and after. As in the Wogalter et
al. study described above, Lesch found little difference in performance
whether training took the form of a written label assigned to each
symbol, a label plus explanatory text, or an accident scenario. Training
also improved response speed.

In a survey of South African workers, London (2003) examined the impact
of brief training on the meaning of symbols and hazard phrases. Here,
the author found no statistical difference in comprehensibility of four
familiar hazard symbols, but did find that training improved
comprehension of one “new” symbol (chronic hazard), and it also
reduced the overall incidence of critical confusion. This study also
demonstrated the benefits of prior workplace training. The author found
that workers with previous training were five times more likely than
others to recognize the SDS as a source of hazard information, and were
also more likely to understand label words and some pictograms and be
able to identify the active ingredient.

7.2.4	Models and recommendations

Key Findings:

In one case, a mandatory training program was more cost-effective and
reached a wider audience than a voluntary alternative.

Training should consider the needs and characteristics of the audience.
Training that accounts for cultural and literacy differences can not
only reduce injuries, but also improve productivity and reduce turnover.

Recent literature includes a number of recommendations for more
effective training.

When designing a hazard communication training program, it helps to
consider what others have done to achieve success. The literature
published since 1997 contains several examples of effective training
programs, along with a host of recommendations on how training programs
can be improved.

In a three-year study, Wolford et al. (1997) examined differences in
training and self-protective practices between painters in
Alaska—which has mandatory health and safety training for
painters—and Oregon and Washington, where such training is voluntary.
Alaska’s regulations require painters who use organic, solvent-borne
coatings to take 16 hours of initial training plus 8 hours of
recertification training every 2 years. This training covers health
hazards, protective equipment, use of fans for temporary ventilation,
and how to obtain and use an SDS. Through observation and
questionnaires, the study found that painters with Alaska’s training
were 2.7 times more likely to wear respirators than untrained painters
were, and 1.65 times more likely to use fans. The authors found other
benefits to Alaska’s mandatory approach as well:

Alaska’s mandatory system tends to reach untrained painters better
than voluntary training programs in other states. In contrast, voluntary
training largely attracts people who have already been trained
before—a subset of “true believers” who are already more
safety-conscious than the average painter.

Mandatory training is more effective than voluntary programs at reaching
non-union painters and those working for companies with fewer than four
employees.

Alaska’s training program has lower recruitment costs than voluntary
programs—only one-tenth of the cost per painter trained. Thus, the
mandatory program is more cost-effective.

Because Alaska requires each painter to pay a portion of the training
fee, the cost to employers is lower per painter trained, compared with
the voluntary programs in other states.

Language and cultural considerations are a growing concern in the field
of health and safety training. At the Dallas-Fort Worth airport, a large
expansion project began in 2002 involving 10,000 workers, roughly half
of whom speak Spanish. To train these workers, a local expert
interviewed over 100 Hispanic workers and designed a program that would
meet their needs better than a conventional training program. The
barriers were more than just a lack of English literacy; many of the
Spanish-speaking workers could not read or write Spanish either. Thus,
rather than relying on written materials, the training program
emphasized hands-on training until an employee could master a task. This
program also used Hispanic instructors, which made trainees feel more
comfortable asking questions. As a result of improved training, this
project experienced less than 10 percent of the lost time injuries that
would be expected for a project of its size and scope, along with many
fewer workers compensation claims (Boone, 2003). As Halcarz (2003)
explains, this training approach was successful because it was
equality-based, recognized the dignity of all employees, and minimized
literacy requirements. In addition to lowering injury rates and
insurance expenses, such an approach can also increase productivity and
promote loyalty. The Dallas-Fort Worth program has been recognized as an
OSHA “National Best Practice” (Halcarz, 2003).

In an example related to HCS, Dean et al. (2002) describe how the Kansas
City (MO) Street and Traffic Division updated its hazard communication
training after employees indicated that the existing program was
insufficient. In this case, the division created a CD-ROM-based training
with on-site photos and employees’ voices. This training is
self-paced, with a proficiency test at the end. At the time of the
article, however, the authors did not have data on how well this new
approach performed.

Other recommendations to improve training include the following ideas:

Weidner (2000) suggests that while many training programs use 70 percent
as the passing score on knowledge tests, this threshold is too low
because it offers a false sense of security and “reinforce[s]
mediocrity as a training objective.” The author recommends a more
“reasonably rigorous” standard of expectation; the exact value may
depend on the difficulty of the test. Two-way feedback also should be
encouraged.

Recognizing that symbols are the items most often recalled from a label,
London (2003) advises a strong emphasis on training for GHS symbols,
particularly the “oxidizer” and “flammable” symbols—which were
reported to be easily confused—and symbols that may generate critical
confusion (eliciting the opposite action—for example, interpreting the
“environmental toxicity” symbol to indicate an area where people can
catch fish).

Bouchard (1997) recommends that employers involve workers on the
workplace safety committee; determine how often they need to repeat
training (how long do people retain information?); and ask trainees to
explain concepts in their own words (e.g., explaining what they read on
an SDS), rather than assessing knowledge by simply asking “Do you
understand?”

To encourage employers to improve training, Fagotto and Fung (2002)
suggest that if companies use good training techniques like interactive
training, real life simulations, and evaluating workers’
understanding—and achieve a low rate of injuries and illnesses—they
should be rewarded with lower premiums for workers compensation
insurance.

7.2.5	Research needs

Studies published since 1997 suggest a continued need for research on
worker safety and health training. Specific recommendations come from
Cohen and Colligan (1998) and Lesch (2003).

After reviewing the literature available as of 1998, Cohen and Colligan
(1998) suggest additional research in the following areas:

Effects of group size and the length and frequency of training.

More information to correlate training with outcomes—e.g.,
retrospective studies of injuries and diseases in workers.

More in-depth studies on hazard training practices and how they relate
to other hazard control measures.

The extent to which industry has implemented OSHA training approaches,
and the success of those programs.

Lesch (2003) suggests that “Future research should look more closely
at how warning, person, and situational factors interact to influence
warning processing and determine whether training programs can be
designed to help counteract factors that prevent adequate processing of
warnings.”

8.	Related Considerations

8.1	Legal considerations

In testimony before the U.S. Senate Subcommittee on Employment, Safety,
and Training, Michelle Sullivan, Chairman of the Society for Chemical
Hazard Communication (SCHC) Board of Directors, notes that the U.S. has
a unique set of issues around label development (Sullivan, 2004). Among
these unique issues are liability and the duty to provide an adequate
warning. Legal considerations have long been considered when developing
product labels and warnings, and have recently become a factor for SDS
development as well. Sullivan expresses support for adopting the GHS in
the U.S., but recommends that these unique issues be kept in mind.

Many textbooks on warnings include information about legal perspectives.
For example, Madden (2006) offers an overview of the manufacturer’s
duty to warn, as does Madden (1999). While much of the discussion and
legal precedent concerns consumer products, some of the basic principles
may be useful when evaluating occupational settings as well.

Another perspective on product liability comes from the insurance
industry. For instance, The Hartford has published a set of tips on
minimizing product liability. Among other things, these tips direct
companies to follow the ANSI Z535.4 standard for product safety signs
and to test their warning labels with real users (The Hartford, 2002).

One important extension of “duty to warn” concerns low-literate and
non-English-speaking populations. What is the manufacturer’s duty to
communicate safety information to these groups? Ross (1995) provides
some examples from relevant case law. In a 1962 decision, a U.S. federal
appellate court established two essential characteristics of a legally
adequate warning: “(l) It must be in such a form that it could
reasonably be expected to catch the attention of a reasonably prudent
man in the circumstances of its use; and (2) the content of the warning
must be of such a nature as to be comprehensible to the average user and
to convey a fair indication of the nature and extent of the danger to
the mind of a reasonably prudent person.” (Ross, 1995, citing Spruill
v. Boyle-Midway, Incorporated, 308 F.2d 79 [4th Cir. 1962]). Other court
decisions have varied.

In some locations (e.g., areas like Miami), the average user may not be
English literate. Therefore, as a general principle, Ross (1995)
suggests that “if a manufacturer is selling a product in areas where
the average user likely will not speak English or possibly not read at
all, it should consider including at least a pictorial or symbol which
identifies the hazard, and, possibly, a word message in a foreign
language.” The author warns, however, that a manufacturer may run some
risk of liability if it includes foreign language labels and these
labels contain inadequate information or are not effectively
communicated. Pictograms may also be useful—particularly for users who
are not literate in any language—but designers must be careful not to
omit important information by relying on simple representations.

8.2	Emerging approaches for hazard communication and control

In the last decade, a new approach to the management of hazardous
chemicals has emerged. This approach, called “control banding,”
involves classifying chemicals into general hazard groups or “bands”
(such as “skin and eye irritants”), then prescribing a specific set
of control measures for a given range of exposures to a chemical within
that group (CDC/NIOSH, 2005).

Control banding was pioneered by the pharmaceutical industry as a way to
manage exposure risks from an ever-increasing number of chemicals in the
workplace—a particular concern in an industry where workers frequently
interact with new substances that have yet to be studied extensively
(Naumann et al., 1996). More recently, the control banding approach was
adopted by the UK Health and Safety Executive (HSE) as a means to help
small- and medium-sized enterprises comply with the Control of
Substances Hazardous to Health (COSHH) safety regulations without
on-site technical experts and expensive exposure measurements (Jackson,
2002). In its COSHH Essentials package, the HSE provides a stepwise
approach to assessing risks, based on standard hazard phrases that the
manufacturer must assigned to a given chemical (HSE, 2005). Based on the
level of risk, the employer must follow a specific set of control
measures (e.g., ventilation, engineering control, or containment)
(Jackson, 2002).

Control banding also has been adopted for international use, targeted
mainly at developing countries where employers may lack technical
expertise in hazard evaluation and control. Together with the ILO, WHO,
and the United Nations Environment Programme, the International
Occupational Hygiene Association (IOHA) developed the International
Chemical Control Toolkit, which provides resources and guidance on
control banding (ILO, 2006).

Although control banding is not part of the GHS, some have suggested
that control banding and the GHS are complementary, and that both
strategies are worth considering when updating the HCS (e.g., Garman,
2005). Among other things, control banding could provide a means to
protect trade secrets without putting workers at risk.

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 Some research articles, standards, and regulations use the term
“symbol;” others use “pictorial,” “pictogram,” or
“pictograph.” Some sources provide distinct definitions for these
terms, as described further in Section <IP_ADDRESS>. However, others
essentially use the terms interchangeably. This report follows the
latter approach.

 Studies differ in how they define “younger” and “older” adults.
For example, some define “older” adults as those over ago 50, while
others define this group as those over 65. For information on the age
ranges in specific studies, see Section <IP_ADDRESS> or consult the studies
that are cited.

 The ANSI SDS used in this experiment reflected an earlier version of
the standard; however, the same 16-section format was in place at the
time.

 ANSI Z535.6 is a new standard; thus, no older versions were available
to review.

 “Mr. Yuk” is a cartoon image created by the Pittsburgh Poison
Center at Children’s Hospital of Pittsburgh (  HYPERLINK
"http://www.chp.edu/mryuk/05a_mryuk.php"
http://www.chp.edu/mryuk/05a_mryuk.php ). The image—a scowling green
face with its tongue hanging out—is commonly used on household
chemicals to deter children from ingesting the product.

 Tactile, olfactory, and gustatory refer to touch, smell, and taste,
respectively.

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