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Whose line is it anyway?

June 28, 2010

It’s a fact of life. People don’t often read safety manuals and warning labels. I am guilty of such neglectful behavior from time-to-time and such occurrences remind me of how important on-the-job training can be – but I’m talking about relevant training. Training that is useful once the person returns to their job. Lots of well-written documentation that is designed to protect manufacturers rather than end-users is useless if it is out of touch with what the user needs to have in front of them, in the form they require it.

Tebeaux (2010) looked at technical documentation from a historical perspective and reviewed safety warnings in tractor operation manuals during the period of 1920-1980 and pointed out that the carefully constructed and often compliance-driven warnings didn’t always work to lower accident rates. The reason the warnings, standing alone, were ineffective is because they were often legally required and designed to indemnify the companies who manufactured tractors. Tebeaux (2010) found that prior to OSHA (whose inception was 1979) cautions and warnings varied substantially and focused primarily on maintenance issues raised to keep the machines running smoothly rather than to protect the operator. Eventually implied warnings, warning plus explanations and finally the focus on operator safety developed in line with the notion of social responsibility of manufacturers, owners and operators of tractors.

Tebeaux (2010) observed that tractor operators did not consistently read the safety manuals and that age, training and the likelihood of taking “short cuts” contributed to the lack of decline in tractor accidents and fatalities. Additionally, Tebeaux (2010) reported that advice regarding the operation of tractors generally came by word of mouth from neighbors and family members through those who were considered “experienced” operators. Finally, Tebeaux (2010) noted that OSHA regulations regarding tractor safety “do not apply to family-owned farms, which still comprise 85-90% of farm operations in the United States” (p. 24).

In the cases Tebeaux (2010) studied, the ethical burden of following the safety manuals and the warnings contained therein could be considered a shared responsibility first belonging to the manufacturer of the equipment (including the technical writers who address safety and compliance needs) and  secondarily to the end user. The manual, according to Tebeaux (2010), must satisfy the legal test of being written at a level commensurate with the average level of education of the average tractor operator. In this situation, the manufacturer (barring any known defect or operating hazard not already disclosed) has satisfied their ethical and moral obligation to the end user. It is the responsibility of the end user to make use of the safety manuals and warnings to the extent necessary. In some cases, normal use of tractors, as they have been designed to function, implies an assumed risk on the part of the operator. That is to say they understand there is some degree of harm possible in operating tractors, they are aware of that possibility and choose to undertake the risk after being duly informed.

However, humans regularly ignore warnings as my experience in the chemical industry has demonstrated. As part of compliance and risk management efforts at the chemical company I worked at years ago, steps were taken on an ongoing basis to ensure all compliance documents, including proper labeling of products, work stations and other areas under the corporate umbrella, were in order. One difficult that arose regularly was to continually try to imagine how end users might incorrectly utilize tools or products. As an example, a new warning was applied to three chemical product labels instructing the user that it would be harmful if they combined these relatively unrelated cleaning products. Because the products were unrelated it hadn’t yet been imagined that users would choose to combine them for any purpose. Yet there was an incident report which developed into litigation-threatening correspondence where an end user had combined the products, producing a gas cloud which caused the user to pass out, necessitating a trip to the emergency room for treatment. While we used to humorously say our jobs were to “save people from themselves” it was only somewhat of a laughing matter as that was indeed what our jobs entailed.

The limits of such necessitated actions arise when a company or manufacturer is intentionally negligent and lives are in jeopardy because of a warning or instruction that was not given; either by design or by omission. As Dragga (1997) pointed out, there are times when technical communicators must understand the ethical implications of taking certain jobs with certain companies in line with what that company produces or sells. Intentional omission of critical safety information by a company is a situation in which the technical communicator faces tough choices as potential whistle blowers. While legal protection is available for whistle blowers, few who have been through the aftermath of blowing the whistle would advise others to undertake such a burden without carefully considering all of the potential consequences.

Resources

Dragga, S. (1997). A question of ethics: Lessons from technical communicators on the job. Technical Communication Quarterly, 6(2), 161-178.

Dumbrowski, P. (2000). Ethics in technical communication. Boston: Allyn and Bacon.

Tebeaux, E. (2010). Safety warnings in tractor operation manuals, 1920-1980: Manuals and warnings don’t always work. Journal of Technical Writing and Communication, 40(1), 3-28.



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