Exploring the New Component Warning Notice

Editor’s Note: Kent Pagel is SBCA’s Legal Counsel and is a partner with the Houston, Texas firm of Pagel, Davis & Hill, P.C. This article shares Mr. Pagel’s perspective on why the Component Warning Notice (CWN) is important to component manufacturers. For questions or concerns regarding the CWN, please contact SBCA at info@sbcacomponents.com.  

All product manufacturers have a duty to warn users as to the risks associated with the product they manufacture. Similarly, component manufacturers (CMs) have a duty to warn installers and others about the safety risks associated with the handling and installation of trusses and components. Thus, consistent with its purpose clause in the SBCA bylaws, SBCA has developed and proposes for widespread use a truss and component risk warning notification program which is referred to as the Component Warning Notice.  

Structural components utilizing lumber (“Components”) can pose hazards to installers, other construction personnel, and bystanders. If not properly handled, installed and braced, Components can fall from heights and injure persons below. Installers can also fall when installing and working from Components, particularly when they are not utilizing fall protection measures. The lack of fall protection was OSHA’s most frequently cited standard in 2023. This is the 13th consecutive year the OSHA Fall Protection standard has topped the list. Examples of hazards involving Components include walking on or supporting oneself from Components lying in a horizontal orientation or not part of a fully installed and braced system. The hazards of falling from Components or falling Components can involve serious injury or death. 

The purpose of a product warning is to alert users to the existence and nature of product risks so that they can prevent harm by appropriate conduct during use. An adequate warning will: (1) alert the user to the severity of the hazard and the likelihood of it being encountered); (2) clearly state the nature of the hazard; (3) clearly state the consequences of the hazard; and (4) provide instructions on how to avoid the hazard. 

On the issue of location of warnings, reason normally suggests that important warnings be placed on the product itself. Booklets, pamphlets, or other information may not end up in the hands of the user, or can be damaged, lost, destroyed, or stuffed in an office drawer. The best practice is therefore to attach warnings on the product itself so that it can be seen before the user encounters the hazard.  

The Building Component Safety Information (BCSI) booklet and the BCSI summary sheets are very good and thorough installation and instructional documents published by SBCA. However, these documents assume some common knowledge on the part of the installer and do not conspicuously warn of the dangers that can exist with respect to Components, particularly where fall protection is not being used by the installer. 

For these reasons, SBCA has developed the Component Warning Notice which includes a warning tag to be affixed to all Components (the “Warning Tag”), and which the Warning Tag through the use of a QR code can be easily scanned by a mobile device referring the user to a warning notice sheet (the “Warning Notice”). The Warning Tag brings the risks to the attention of the installer and the Warning Notice explains in greater detail the nature of the risks associated with Components. SBCA is further recommending the Warning Notice be included in the manufacturer’s Jobsite Package. SBCA’s proposed Warning Tag can be viewed at https://pubs.sbcacomponents.com/products/component-warning-notice-tag-1-000-tags and the proposed Warning Notice can be viewed at https://pubs.sbcacomponents.com/products/component-warning-notice-50-copies. The SBCA Warning Notice website (the “Warning Website”), which is even more comprehensive, can be viewed at https://componentwarningnotice.com/.  

Together, the Warning Tag, the Warning Notice, and Warning Website (collectively the “Warning Documentation”), coupled with the cross references to BCSI, will warn the installer as to the requirement to use Fall Protection and the fall hazards associated with Components, and in particular the specific dangers in terms of handling, installing, and walking on or about Components, while at the same time providing the manufacturer of such Components the ability to assert that all of the warnings contained within the Warning Documentation should have been read before the installer used the Components and that they can assume this will be done.  

Each of the Warning Tag, Warning Notice, and the Warning Website support the usage of the other two, while the Warning Notice and Warning Website reference one another as well as the Warning Tag. This creates a triangulation effect for maximum awareness of the hazards of Components for the installer. Each of the Warning Documentation utilizes a consistent approach with specific warning language and usage of specific colors as stipulated in ANSI Z535.  

SBCA realizes it is no small request to ask CMs to alter their manufacturing processes and procedures to affix a Warning Tag and to otherwise include a Warning Notice with each Jobsite Package. The goal for this effort is to prevent injury to installers and others when working with Components. 

For more information or if there are questions, please visit www.componentwarningnotice.com, www.pubs.sbcacomponents.com, www.sbcacomponents.com/CWN, or contact SBCA at info@sbcacomponents.com.