Update to OSHA’s Process Safety Management Regulation. Part 12: Definition of RAGAGEP

In this post we continue our discussion of the proposed changes to OSHA’s Process Safety Management standard. We are now up to the section in which OSHA discusses the meaning of RAGAGEP: Recognized and Generally Accepted Good Engineering Practice.

Not only OSHA, but the EPA (Environmental Protection Agency) and the American Chemistry Council (ACC) use the concept of RAGAGEP. The ACC includes RAGAGEP in its Responsible Care Process Safety Code. The EPA information is available here.

In its Stakeholder agenda OSHA states that it wishes to clarify exactly what RAGAGEP means, and how it can be best incorporated into the PSM standard. The pertinent section is as follows,

Amending paragraph (b) to include a definition of RAGAGEP;

(Paragraph (b) of the standard is to do with definitions.)

OSHA Guidance

The PSM Standard, 29 CFR 1910.119, directly references or implies the use of RAGAGEP in three provisions:

(d)(3)(ii): Employers must document that all equipment in PSM-covered processes complies with RAGAGEP;

(j)(4)(ii): Inspections and tests are performed on process equipment subject to the standard's mechanical integrity requirements in accordance with RAGAGEP; and

(j)(4)(iii): Inspection and test frequency follows manufacturer's recommendations and good engineering practice, and more frequently if indicated by operating experience.

In addition, (d)(3)(iii) addresses situations where the design codes, standards, or practices used in the design and construction of existing equipment are no longer in general use. In such cases, the employer must determine and document that the equipment is designed, maintained, inspected, tested, and operating in a safe manner.

As used in the PSM standard, RAGAGEP apply to process equipment design and maintenance; inspection and test practices; and inspection and test frequencies.

Previous Guidance

In May 2016 issued the guidance document RAGAGEP in Process Safety Management Enforcement. This is a lengthy document. The Enforcement Considerations section alone contains 16 paragraphs. The following are the first four points from that section.