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”?
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opinion, shared by lots of folks throughout industry, the problem is that OSHA machine safety regulations are woefully out of date with current technology.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?
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?
Contact: www.jbtitus.com for “Solutions for Machine Safety”.
- Events & Awards
- Magazine Archives
- Oil & Gas Engineering
- Salary Survey
- Digital Reports
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