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”?


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opinion, shared by lots of folks throughout industry, the problem is that OSHA machine safety regulations are woefully out of date with current technology.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 Top Plant program honors outstanding manufacturing facilities in North America. View the 2015 Top Plant.
The Product of the Year program recognizes products newly released in the manufacturing industries.
The Engineering Leaders Under 40 program identifies and gives recognition to young engineers who...
Safety for 18 years, warehouse maintenance tips, Ethernet and the IIoT, GAMS 2016 recap
2016 Engineering Leaders Under 40; Future vision: Where is manufacturing headed?; Electrical distribution, redefined
Strategic outsourcing delivers efficiency; Sleeve bearing clearance; Causes of water hammer; Improve air quality; Maintenance safety; GAMS preview
SCADA at the junction, Managing risk through maintenance, Moving at the speed of data
Safety at every angle, Big Data's impact on operations, bridging the skills gap
The digital oilfield: Utilizing Big Data can yield big savings; Virtualization a real solution; Tracking SIS performance
Applying network redundancy; Overcoming loop tuning challenges; PID control and networks
Driving motor efficiency; Preventing arc flash in mission critical facilities; Integrating alternative power and existing electrical systems
Package boilers; Natural gas infrared heating; Thermal treasure; Standby generation; Natural gas supports green efforts

Annual Salary Survey

Before the calendar turned, 2016 already had the makings of a pivotal year for manufacturing, and for the world.

There were the big events for the year, including the United States as Partner Country at Hannover Messe in April and the 2016 International Manufacturing Technology Show in Chicago in September. There's also the matter of the U.S. presidential elections in November, which promise to shape policy in manufacturing for years to come.

But the year started with global economic turmoil, as a slowdown in Chinese manufacturing triggered a worldwide stock hiccup that sent values plummeting. The continued plunge in world oil prices has resulted in a slowdown in exploration and, by extension, the manufacture of exploration equipment.

Read more: 2015 Salary Survey

Maintenance and reliability tips and best practices from the maintenance and reliability coaches at Allied Reliability Group.
The One Voice for Manufacturing blog reports on federal public policy issues impacting the manufacturing sector. One Voice is a joint effort by the National Tooling and Machining...
The Society for Maintenance and Reliability Professionals an organization devoted...
Join this ongoing discussion of machine guarding topics, including solutions assessments, regulatory compliance, gap analysis...
IMS Research, recently acquired by IHS Inc., is a leading independent supplier of market research and consultancy to the global electronics industry.
Maintenance is not optional in manufacturing. It’s a profit center, driving productivity and uptime while reducing overall repair costs.
The Lachance on CMMS blog is about current maintenance topics. Blogger Paul Lachance is president and chief technology officer for Smartware Group.
This article collection contains several articles on the vital role of plant safety and offers advice on best practices.
This article collection contains several articles on the Industrial Internet of Things (IIoT) and how it is transforming manufacturing.
This article collection contains several articles on strategic maintenance and understanding all the parts of your plant.
click me