From: Dan Kuespert <dkuespert**At_Symbol_Here**JHU.EDU>
Subject: Re: [DCHAS-L] How long to keep old standards?
Date: Tue, 18 Aug 2015 13:10:52 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 578A4AB4-37D8-43FA-A34B-AF3D8B283A4C**At_Symbol_Here**

Hot work is another area where a 1963 standard is cited. Took me days to track down the right document one time when it became an issue with an inspection.

I believe OSHA can update standards at any time provided they follow the Administrative Procedures Act and associated legislation, just like other Federal regulations. They're just REALLY inefficient at doing so, partially because changing or setting a standard is always a political hot potato and partially because OSHA is perennially starved for funds. It's a fairly onerous process to put out or change a reg, but some agencies seem to be better at it than others.

The place to go for antique standards is the standards developer—they usually maintain copies in their files, if not for public consumption, for use by their standards committees in developing new versions. ANSI's library also keeps a fair amount of historical material, I believe.


Dr. Daniel R. Kuespert
Homewood Laboratory Safety Advocate
Krieger School of Arts & Sciences/Whiting School of Engineering
The Johns Hopkins University
103G Shaffer Hall
3400 North Charles St.
Baltimore, MD 21218
(410) 516-5525

On Aug 17, 2015, at 22:32, Eileen Mason <lnmsn8**At_Symbol_Here**GMAIL.COM> wrote:

OSHA standards cite a specific version when a voluntary standard is incorporated by reference. Voluntary standards are easier to update than OSHA standards, which really Do require an act of Congress.  So if OSHA cites an antique standard, it might be hard to find a copy of that actual document.  

For example, see 1910 Subpart H - compressed gases:


"Inspection of compressed gas cylinders." Each employer shall determine that compressed gas cylinders under his control are in a safe condition to the extent that this can be determined by visual inspection. Visual and other inspections shall be conducted as prescribed in the Hazardous Materials Regulations of the Department of Transportation (49 CFR parts 171-179 and 14 CFR part 103). Where those regulations are not applicable, visual and other inspections shall be conductedin accordance with Compressed Gas Association Pamphlets C-6-1968 and C-8-1962, which is incorporated by reference as specified in Sec. 1910.6.


"Compressed gases." The in-plant handling, storage, and utilization of all compressed gases in cylinders, portable tanks, rail tankcars, or motor vehicle cargo tanks shall bein accordance with Compressed Gas Association Pamphlet P-1-1965, which is incorporated by reference as specified in Sec. 1910.6.



"Safety relief devices for compressed gas containers." Compressed gas cylinders, portable tanks, and cargo tanks shall have pressure relief devices installed and maintained in accordance with Compressed Gas Association Pamphlets S-1.1-1963 and 1965 addenda and S-1.2-1963, which is incorporated by reference as specified in Sec. 1910.6.

On Mon, Aug 17, 2015 at 6:17 PM, Margaret Rakas <mrakas**At_Symbol_Here**> wrote:
I am moving offices and have probably 30 years' worth of ANSI/NFPA/CGA standards.  I am fine with keeping those no longer updated (like the NFPA standard on oxidizer storage) but is there any point in keeping the last 3 editions of (for example) the ANSI standard on eyewashes and safety showers?  I have limited space and no time to peruse the history/evolution of safety and compliance a practices...
Many thanks for your thoughts on this-

Sent from my iPhone

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