OSHA: The 1971 Lawyer's Full Employment Act

Incorporated by Reference

 Three words that can turn your world upside down

When I first received a printed, bound version of OSHA 1910, I sunk in my chair at the assignment of having to get command of this document. It became my responsibility because I was the new kid at work, with a freshly minted college degree and a customer list of zero. The OSHA book was considerably larger than the South Bend, Indiana phone book, with fine print to match. 

After leafing through the book, I found the crane section 1910.179. Much to my relief, OSHA 1910.179 was about 11 type written pages long, about 7300 words. I thought confidently that I ought to be able to knock it out by lunch. 

In spite of the "legalese,” tortured sentences and frequent circuitous logic, by lunch I told my Dad that I was "on top of it." Little did I know what I didn't know. The eleven pages from 1910 were only the tip of the iceberg. Some time later I was reading a trade journal and came across an article on "Incorporation by Reference.” Upon completion of reading that article, my life became absurdly more complicated.

“Incorporation by reference is the act of including a second document within another document by only mentioning the second document. This act, if properly done, makes the entire second document a part of the main document.” 

Russian Matryoshka Dolls

In the future, I’ll periodically refer to this as the “Russian Matryoshka Doll Inversion.” I call it that because on one hand, like Russian Matryoshka dolls, seemingly every document has one or more documents buried inside the current document. But unlike the Matryoshka doll, frequently the referenced document buried inside the current

document is far, far larger than the initial document.

In addition to the “Matryoshka Doll Inversion” is the “Family Tree Syndrome.” This is when the first document is referenced to five, second  tier documents, which are then each referenced to eight third tier documents, and on, and on and on. The final number of pages is probably near infinite. That’s just a guess because I’m sure nobody has lived long enough to list all the incorporated documents, much less counted the pages. 

These Specs Cost Big Money!

By the way, the OSHA documents are free, public domain documents (if you get an on-line PDF version), but all the other documents are copyrighted and privately owned by the likes of ANSI, ASME, CMAA, etc. Each of these document cost between $50 and $400 dollars for a simple PDF copy. To make a bad situation worse, they are all revised every couple of years, usually 90% unchanged. The problem is that you won’t know what parts have been changed until you buy the new version.

Here's the List

Well, so much for my rant. You would have thought the “On-Line, Information Age” would have decimated this ridiculous system, but it hasn’t. So here’s a link to Section 1910.6 Incorporation by Reference from the current (2016) version of OSHA 1910 spec. It lists over 200 additional specifications Incorporated by Reference thereby making all these additional specs part of the OSHA 1910 specification.

By the way, regarding cranes specifically, 1910.6 incorporates by reference ANSI/ASME B30.2 which references CMAA 70, which in-turn referenced 24 other specs including AWS, AGMA, NEC, etc.

Although the acronym OSHA stands for Occupational Safety and Health Administration, with an infinite number of documents “incorporated by reference” it more accurately should have been called The Lawyers Full Employment Act of 1971.