From time to time it is worth revisiting the small things that routinely get picked up during machinery inspections and asking a simple question: does this actually matter?
That is the position we have recently taken at Knox Thomas in relation to text on the background of an emergency stop actuator and the colour of any indication showing the direction of unlatching. After review, we have decided that we will no longer identify these as PUWER non-compliances.
The reason is not that standards are of zero value. They are. Nor is it that good design practice should be ignored. It should not. The reason is that these particular points, in our view, have little to no bearing on actual risk, and health and safety loses credibility when minor technical observations are treated as though they carry the same weight as issues that genuinely expose people to harm.
What the Standard Actually Says
The relevant wording regarding the text on the emergency stop background comes from EN ISO 13850:2015, clause 4.3.7, which states: “Neither the actuator nor the background should be labelled with text or symbols.” That sentence is often repeated as though it settles the matter entirely. In practice, it does not.
The key word is “should”. Language used within standards is chosen deliberately. “Shall” and “must” indicate a requirement. “Should” indicates a recommendation. That does not make it meaningless, but it does make it different. It tells you what the preferred arrangement is, not that any departure from it automatically becomes a meaningful failure, let alone something that necessarily ought to be raised as a PUWER non-compliance in its own right.
This distinction matters because too much health and safety discussion is reduced to whether something matches a line in a standard or piece of legislation, rather than whether it creates or contributes to a real risk. Those are not always the same thing. Standards are valuable, but they are a means to an end. The end is risk reduction, not box ticking.
Why the Recommendation Exists
It is not difficult to see the likely thinking behind the recommendation. The argument, presumably, is that when an emergency stop is needed, the person reaching for it should not be distracted by text or symbols on the actuator or its background. On paper that makes sense. In reality, it feels far less convincing.
The same section of the standard also states: “When it is necessary to identify the direction of unlatching of the actuator (button) then this identification shall have the same or nearly the same colour as the actuator.” That wording is stronger. It uses “shall”, not “should”, and within the standard that clearly makes it more prescriptive.
Even so, we will no longer be identifying that point as a PUWER non-compliance either. The reason is much the same. If an emergency stop is visible, accessible, recognisable and functions correctly, then a minor difference in the colour of an unlatching direction indicator does not, in itself, create a meaningful safety issue. It does not stop the emergency stop from being found. It does not stop it from being pressed. It does not prevent the machine from being brought to a safe state. In practical terms, the risk effect is negligible.
Free Tool
Simple but Powerful PUWER Assessment App
A simple, easy-to-use app for checking PUWER compliance — usable on Apple, Android, and desktop browser. No intensive auditing or complicated report writing.
How People Actually Behave Around Emergency Stops
One well known manufacturer of machinery safety components has suggested that this requirement for unlatching direction identification “avoid[s] confusion between actuation (e.g., pressing an actuator) and releasing (e.g., turning an actuator).” Again, on paper that could make sense. In reality, it doesn’t seem so convincing.
Anyone who works in industry knows what an emergency stop looks like. A red mushroom actuator, often on a yellow background, is one of the most recognisable safety features in manufacturing. It is designed that way precisely so that it can be identified immediately, without thought and without explanation. In a genuine emergency, nobody is pausing to study lettering on a backing plate, or going to be confused by rotation direction arrows before pressing the large red button in front of them. The suggestion that the presence of these additional markings materially interfere with emergency response does not stand up well when compared with how people actually behave around machinery.
That is really the crux of it. The practical risk posed by these issues is negligible at best. If the emergency stop is visible, accessible, recognisable, and works properly, then its safety function is intact. The presence of text on the background plate, or a minor colour mismatch on an unlatching direction indicator, does not meaningfully alter that.
Our Position Going Forward
This is why we are changing our position. We are not saying it is best practice to fill the area around emergency stop actuators with unnecessary wording. Nor are we saying that clear and consistent presentation does not matter at all. We are saying that where text is present, or where an unlatching direction indicator is not the same colour as the actuator, and where the actuator is still clearly recognisable and fully functional, we do not consider those points alone to justify being written up as PUWER non-compliances. Some auditors may continue to do so. That is their judgement. It is no longer ours.
That is where we think the conversation becomes more difficult, and more important.
Trust, Responsibility and the Limits of Control
If the only answer to safety is to keep adding controls until people are physically unable to make a poor decision, then what we are really saying is that we do not trust them. We are saying that the operator cannot be expected to understand risk, exercise judgement, or take responsibility within their role. In the short term that can feel like a safe and defensible position. In the long term it creates exactly the sort of culture many businesses say they do not want: one where responsibility sits everywhere except with the individual actually doing the work.
At Knox Thomas we do not think employees should be treated like children. If they currently need that level of safeguarding, then the answer should not always be to design more and more of it into the machine or the procedure. Sometimes the better answer is to improve the team. That means better recruitment, better expectations, better training, and a working environment that encourages ownership rather than dependency.
The Case for Investing in People Over Procedures
That may also mean some awkward truths for employers. If you want a workforce that can be trusted to exercise sound judgement, then you need to train and recruit accordingly. Higher calibre people often cost more. Better salaries may attract more responsible candidates. Better candidates hopefully need less handholding, make fewer poor decisions, and are less likely to injure themselves. Over time, that can reduce the need for layers of supervision, procedural overkill and defensive health and safety bureaucracy. In other words, spending more in one area may allow you to spend less in others, while ending up with a safer and more capable organisation.
That argument will make some people uncomfortable because it cuts against a common instinct in health and safety, which is to assume that more control is always better control. We do not accept that as a blanket truth. Sometimes more control is simply more control. Sometimes it may reduce risk. Sometimes it just reduces autonomy, weakens responsibility and makes machinery harder to use without delivering any meaningful safety benefit in return.
Why This Small Point Reflects a Much Larger Divide
That is why this emergency stop point matters, even though on its face it is quite minor. It is a useful example of a much bigger divide in approach. One approach asks, “Does this match the wording?” The other asks, “Does this affect risk?” We believe the second question is the one that should lead.
What Actually Matters With Emergency Stops
None of this means emergency stops themselves are a minor subject. Far from it. What matters is that they are where they need to be, that they are obvious, that they can be reached quickly, and that they reliably stop hazardous movement when required. It matters that operators can recognise them instantly. It matters that the device is not obscured, not poorly positioned and not purely decorative. It matters that the emergency stop function actually performs as intended within the control system. Those are the issues that deserve attention because those are the issues that genuinely influence outcomes when something goes wrong.
Against that, text on a background plate, or a minor colour mismatch on an unlatching direction indicator, is simply not a serious issue. We have never seen anyone criticised over these points in any meaningful real-world sense, and the discussions around them tend to happen between people who know the standards very well, not because an actual incident or operational problem has brought the issue to life. This is not a problem emerging from shop-floor reality. It is, more often, a point of interpretation discussed by specialists.
Risk First, Not Rules First
So our position is straightforward. We will still recognise the wording in EN ISO 13850. We will still understand why these recommendations and requirements are there. But we will no longer elevate these points into PUWER non-compliances where the actual risk is negligible and the emergency stop remains fully effective.
Health and safety professionals in industry have enough to deal with already. Time and attention should go to matters that genuinely change the level of risk on site. If we spend too much effort on technicalities that have little practical consequence, we undermine the very thing we are supposed to be improving. Good health and safety is not about seeing how many deviations can be listed. It is about understanding what matters, applying judgement, and keeping people safe in a way that remains connected to the real world.
That is the basis for the change in our approach, and we think it is the right one.
