waiting to happen?
Why wait, the incursion accidents have already happened.
The hold short instruction is infact an unsafe clearance in itself. You should not be given an intermediate limitation as your taxi clearance should be something like "taxi to holding position Xray One" after which you can, if you like have the hold short of Runway 12 type of thing. What you cannot have is cleared to runway 17, hold short of Runway 12 at Xray one, as that is a broken clearance. At least in safety terms you cannot have it, but some of the intermediate clearances to appear in PANS ATM.
However, as long as the US stays with that phrase, then US carriers abroad will always risk getting squashed by somebody else