OSHA safety regulations: Incorporation by reference-Do I need to know?

Machine safety OSHA regulations, 29 CFR 1910.XXX, have been in place since the beginning of OSHA in the early 1070’s. So, what’s the problem, and what the devil is “incorporation by reference”?

05/16/2011


Logo for U.S. Occupational Safety and Health Administration includes the OSHA web address, www.osha.gov.Machine safety OSHA regulations, 29 CFR 1910.XXX, have been in place since the beginning of OSHA in the early 1070’s. On the other hand, voluntary consensus standards have been in place for decades preceding OSHA and they have regular update cycles of every three to five years. The OSHA regulations have basically not changed since adoption and OSHA declares them to be the basic minimums for machine safety. So, what’s the problem and what the devil is “incorporation by reference”?

     In my opinion, shared by lots of folks throughout industry, the problem is that OSHA machine safety regulations are woefully out of date with current technology. Do you agree?

J.B. Titus, CFSE     Even OSHA agrees – so let’s look into at least two ways OSHA tries to keep up with current technologies and methodologies for machine safety. First, I think a quick look will reveal that OSHA openly reserves the right to reference consensus standards whenever they investigate or cite violations. Several places can be found on their web site where they reserve this right. A lot of people think this is too broad of a reference and causes manufacturers to consider incorporating too many standards.

     Secondly, OSHA reserves the right to “incorporate by reference” various consensus standards, thereby, the consensus standard referenced is considered the law. Several examples of this situation can also be found on the OSHA web site. Any voluntary consensus standard referenced by OSHA is therefore considered the same as a regulation and becomes the basic minimum for machine safety.

     Now – the question of the day! If a voluntary consensus standard is incorporated by reference by OSHA and that consensus standard references an IEC or ISO standard, does that international standard become enforceable by OSHA?

     Let’s hear some answers?

What’s your opinion?

     Submit your ideas, experiences, and challenges on this subject in the comments section below. Click on the following text if you don't see a comments box, then scroll down: Incorporation By Reference – Do I Need To Know?

     Did you see the Safety Integration Webcast?

Related articles:

How To Integrate Safety

Is OSHA Rear View Mirror Enforcement?

Assistant Secretary David Michaels Remarks

Machine safety... who is responsible?

Contact: www.jbtitus.com for “Solutions for Machine Safety”.



No comments
The Engineers' Choice Awards highlight some of the best new control, instrumentation and automation products as chosen by...
The System Integrator Giants program lists the top 100 system integrators among companies listed in CFE Media's Global System Integrator Database.
Each year, a panel of Control Engineering and Plant Engineering editors and industry expert judges select the System Integrator of the Year Award winners in three categories.
This eGuide illustrates solutions, applications and benefits of machine vision systems.
Learn how to increase device reliability in harsh environments and decrease unplanned system downtime.
This eGuide contains a series of articles and videos that considers theoretical and practical; immediate needs and a look into the future.
Controller programming; Safety networks; Enclosure design; Power quality; Safety integrity levels; Increasing process efficiency
Additive manufacturing benefits; HMI and sensor tips; System integrator advice; Innovations from the industry
Robotic safety, collaboration, standards; DCS migration tips; IT/OT convergence; 2017 Control Engineering Salary and Career Survey
Featured articles highlight technologies that enable the Industrial Internet of Things, IIoT-related products and strategies to get data more easily to the user.
This article collection contains several articles on how automation and controls are helping human-machine interface (HMI) hardware and software advance.
This digital report will explore several aspects of how IIoT will transform manufacturing in the coming years.

Find and connect with the most suitable service provider for your unique application. Start searching the Global System Integrator Database Now!

Infrastructure for natural gas expansion; Artificial lift methods; Disruptive technology and fugitive gas emissions
Mobility as the means to offshore innovation; Preventing another Deepwater Horizon; ROVs as subsea robots; SCADA and the radio spectrum
Future of oil and gas projects; Reservoir models; The importance of SCADA to oil and gas
Automation Engineer; Wood Group
System Integrator; Cross Integrated Systems Group
Jose S. Vasquez, Jr.
Fire & Life Safety Engineer; Technip USA Inc.
This course focuses on climate analysis, appropriateness of cooling system selection, and combining cooling systems.
This course will help identify and reveal electrical hazards and identify the solutions to implementing and maintaining a safe work environment.
This course explains how maintaining power and communication systems through emergency power-generation systems is critical.

(copy 5)

click me