Interpreting baby carrier regulations and other regulations can be as much art as science. These standards are written and maintained by experts from fields such as test labs, government organizations, consumer advocates, compliance attorneys, trade organizations, and product engineers. The goal in any standards is to maximize product safety in clear, concise, and precise ways.
Committees at the various standards-writing organizations spend hours, months, and even years choosing specific words and symbols, honing the details of required testing tolerances, and more.
ANSI labels enter baby carrier regulations via ASTM standards
In 2022, the ASTM standard for infant slings (F2907) was updated. One of the updates was a requirement that labels follow the ANSI standard for labels, Z535. This standard is cited in OSHA regulations to ensure that things like “wet floor” signs or hazard symbols on dangerous chemicals are clear and impactful.
Eventually, all US baby carrier regulations will use this standard as the CPSC and ASTM seek to implement it across standards. This is because the writers of this ANSI standard are considered the experts on warning labels. The goal is for all children’s products to have impactful, evidence-based safety labels.
Room for interpretation in baby carrier regulations and the difficulty for testing labs
The first thing to remember is that test labs are run by human beings, often with differing backgrounds. The people evaluating the products have read the standards closely and been trained in interpreting the standards, but each person is an individual. Often labs have several people doing the same tests not only in the same lab, but in labs at facilities on different continents.
It’s possible that even the same lab technician may see a standard slightly differently from one day to the next. Picture yourself with a fabric label in front of you with a caliper or ruler trying to determine if the text height is 4.8mm tall or 5mm tall. It’s not an easy task. And for labs to maintain their CPSC accreditation, they need to interpret the standards precisely, even in a case like this, where it seems the .2mm should not be a big deal.
Now, let’s talk about standards. Standards often have multiple parts. There is the body of the standard itself, which describes the scope and requirements. Then there may be example images and appendixes to compliment the standard.
Warning statements are not always straighforward
The ANSI standard, the ASTM baby carrier standards, and many other standards outline requirements for warning labels and warnings within instructions. Sometimes, standards require exact wording. Other times, the standards only specifies that certain things be “addressed” in warnings but do not require specific words used while addressing them.
When the standard does not require specific wording, labs have to decide, during product testing and evaluation, if the verbiage chosen by a company meets the requirements of the standard. This sometimes leaves room for interpretation and differences of opinion.
And sometimes, minute details can be missed when a standard first changes. Or, there can be minor conflicts or confusing details written into the standards. When this happens, the labs learn from one another and hone their processes. And occasionally, it means that an item that passed testing one year will not pass the following year.
The hidden complexities of the word WARNING
The ANSI Z535.4 standard is an excellent example of how a close, nitpicky reading of a standard can create dissonance. This may get a little confusing — these kind of nerdy details fascinate some people and overwhelm others.
Remember, each word of these standards is closely considered and reviewed regularly. A great deal of time and money are spent ensuring they are clear and consistent. Still, there can be points of confusion. In truth, that is why standards become so long and seemingly convoluted at times.
A close and careful reading of the ANSI standard means reading not only the body of the text, but the appendixes. The alignment of the safety alert symbol and the word “WARNING” is addressed in two separate sections of the standard.
6.3 A safety alert symbol, when used with the signal word, shall precede the signal word. The base of the safety alert symbol shall be on the same horizontal line as the base of the letters of the signal word. The height of the safety alert symbol shall equal or exceed the signal word letter height.
— ANSI Z535.4
B2 Signal Word Panel Arrangement: For those signal words that require the use of the safety alert symbol (i.e., DANGER, WARNING, and CAUTION), the safety alert symbol and signal word should be positioned close together and centered in the signal word panel. See Figures B1 and B2. For those signal words that do not require the safety alert symbol (i.e., NOTICE, SAFETY INSTRUCTIONS), the signal word should be positioned in the center of the signal word panel.
— ANSI Z535.4
In 2022, the revised ASTM F2907-22 standard was brand new. There are a lot of words in both the ANSI standard and the F2907 standard; reading and interpreting them involved a lot of notes and cross-referencing. Parts of the standard discussed alignment of words and symbols. Other parts reference centering the words and symbols. The words “shall” and “should” are used in different parts of the standard. And the ASTM standard only references certain parts of the standard — and also specifies changes to the ANSI standard within the body of the ASTM standard. It is convoluted and complex.
Over time, labs became more familiar with the details of the standard. Eventually, a lab tech realized that a closer reading of the standard showed that the examples and suggestions in the appendixes were NOT the same as the verbiage in section 6.3. Perhaps that tech was part of the ANSI committee at one point? I don’t know, but whoever they were, they understood that section 6.3 is in the BODY of the standard, and therefore required. Sections A and B are APPENDIXES, and therefore offers suggestions.
In section 6.3 of the standard, it states that the symbol should be on the “same horizontal line as the base of the letters of the signal word.” A few months after the standard was implemented, some labs determined that this meant that the base of the triangle should align with the bottom of the letters in the word, even if the warning symbol was larger than the word.
This interpretation contradicts some of the example warnings shown in the standard and in Annexes A and B. This means that using the images provided as examples in the standard can result in a layout that fails testing. Additionally, in section B, it states, “Keep the safety alert symbol and signal word next to each other and centered in the signal word panel.” This is a suggestion to center the word and symbol. It’s not clear whether the focus should be on centering the word, or on centering the symbol, and at the time of writing, I await clarification about this point.
Clarification from the ANSI committee
I wrote to the ANSI committee for clarification, and they explained to me the difference between the requirements of the body of the standard and the suggestions in the appendixes. They noted the discrepancy and told me they’ll address and clarify the standard in committee.
Aligning the base of the safety alert symbol with the base of the signal word text is mandatory. 6.3 statements regarding the safety alert symbol preceding the signal word and appearing on the same horizontal line as the base of the letters of the signal word are “shall” statements, so this positioning is required to conform with the standard.
Centering is not technically mandatory. There are no “shall” (mandatory) statements addressing centering in the signal word panel. The related wording and figures in the body of the standard are phrased as examples. Annex B is an informative annex (that is, it does not include any mandatory requirements). In addition, the recommendations in B2 are “should” statements, meaning they address recommended practices rather than requirements. Signal word panel contents that are not precisely centered are not technically in violation of the standard.
Horizontally centering the combined [symbol + word] is typical. The Z535 standards include many examples of the combined [symbol + word] horizontally centered. Vertical alignment of the combined symbol/word is more mixed in the examples – the vertical alignment in many of the examples with a taller safety alert symbol appears to be based on visual balance rather than exact vertical centering of either individual component or the combination.
The committee took the time to share additional these helpful design tips, some of which I had not considered — specifically, that graphics programs often will align text in ways not in compliance with the standard, even when using “align middle” and “align center.”
Practical tip (NOT addressed in Z535.4):
Not addressed in the standard, but in case it’s helpful for your members, the way I typically approach alignment when designing a safety label is:
Throughout, be aware of how the graphics software handles text boxes to be sure that the actual edges of the word are aligned, rather than a larger text box. (E.g., in Illustrator, aligning to “glyph bounds” rather than the text bounding box.)
- Bottom align the safety alert symbol and the signal word so they are on the same baseline.
- “Group” the safety alert symbol and signal word together.
- Center the grouped [symbol and word] both horizontally and vertically within the signal word panel.
Reading the standard with even closer attention to detail creates additional nitpicky questions. It’s imperative that any label we provide to members pass testing at all test labs and with all lab techs. Labels, registration cards, and other written content can fail testing if they do not meet exact measurement and alignment requirements.
First, I created the hazard symbol — an exclamation point inside a black triangle. I realized there is no specific guidance in the standard about this warning symbol, and I wondered whether there is a universal standard for these warning symbols. There are example symbols shown in the ANSI standard.
- Does it matter whether the triangle has rounded corners?
- Is there a requirement for the size or placement of the exclamation point inside of the triangle?
- Is there a particular ratio necessary for the warning triangle to be “correct?”
After making note of this question, I typed the word “WARNING” and vectorized it so I could align the bottom of the triangle with the letters. However, the letters were slightly different sizes. I switched to a monospace font, in which the letters are of equal width — but they were still slightly different heights.
It was easy to ensure that the height of the shortest letter exceeded the minimum size requirements for the standard. But when it came to aligning the triangle, I was unsure of how to interpret the standard. I saw a few options:
- horizontally align the bottom of the triangle with the bottom of the letter sitting lowest
- horizontally align the bottom of the triangle with the bottom of the majority of the letters
- horizontally align the bottom of the triangle with the average between the two
- use a different font size for some letters to ensure they were aligned evenly on the bottom
- manually raise the letters that “stuck out” along the bottom to create an equal baseline.
Monotype fonts are optimized for readability. When you begin manipulating letter sizes or the baseline of a font, it often causes they eye to “skip” a little. The brain notices something not quite right and it reduces comprehension and impact, which is counter to the intent of the standard. Additionally, in Annex B, section B.3.3.9, it says, “The correct spacing between lines of text, between words, and between letters helps to make a word
message easier to read.”
Here are some examples of these options. The images in the yellow/orange boxes show the different alignments more clearly:
Continued investigation into baby carrier regulations and requirements
I am currently awaiting clarification from ANSI about a few more items.
While these questions are nitpicky, it’s important for us to avoid a situation where some labs accept these labels and others reject them, as BCIA members test their carriers at different labs across the world.
We will print new labels and send updated templates to anyone who has purchased our template as soon as we get answers to the following questions:
- Regarding the alignment of the triangle with the “WARNING” text. How does the lab determine alignment? Can the label fail testing if the triangle is not bottom-aligned with all letters? Is it preferable to manipulate the font in order to achieve this, or to maximize readability?
- How should the word “warning” and the symbol be aligned vertically in the bounding box?
- Are there any requirements for the warning symbol (triangle and exclamation point) that could cause the label to fail testing if not followed?
What is the bigger lesson in this?
This is a single example of the complexities of understanding baby carrier regulations. Even carefully constructed standards can have discrepancies, typos, or other errors.
It’s impossible to notice all of of the details in a standard and how they might go together or be interpreted differently by individuals at different labs.
Ultimately, there is no single “authority” on what is “right” in these cases. Often, the CPSC (which enforces the law) will defer to the standards committees. Other times it’s assumed the labs are the experts. Yet other times it’s recommended to work with a compliance auditor or a product compliance attorney.
In the end, each of these people are individuals who will have differing interpretations, and most people don’t have the time or energy to dive into these small details. Usually, they are irrelevant — until a lab fails a carrier because they have a different interpretation of the standard. When that happens, these details become very relevant and important, no matter the size of the brand whose product has failed testing.
The BCIA will continue to advocate for baby carrier companies and dive into these exhausting details. We are here to support you in understanding baby carrier regulations and compliance — even when it’s convoluted and crazymaking.
Stay tuned for more information as we continue to chase the answers to these questions.
If you wish to read the standards yourself, you can purchase the ASTM F2907-22 standard, the ANSI Z535.4-2011 standard, and the ANSI Z535.6-2011 standards.