Inspectioneering Journal

From Student to Expert: How to Utilize Your Internal Engineering Standards Program to Train the Next Generation

By Maria Rennillo, Engineering Solutions Lead at The Equity Engineering Group, Inc. This article appears in the November/December 2022 issue of Inspectioneering Journal.


Operations personnel are responsible for an ever-increasing number of tasks to ensure their facilities run safely and efficiently. The increased workload paired with decreased staffing requirements can lead to overlooking a very important component of site operations: developing the next generation of subject matter experts (SMEs). While developing training programs can seem daunting, a well-managed internal standards program can become a key aspect of an organization’s training program.
Internal standards often serve to create a set of engineering design specifications for an organization’s site(s). The wealth of knowledge that can be incorporated into internal standards makes them an ideal resource for internal training initiatives and allows organizations to maximize the return on their investment in the standards program.


Internal Standards as RAGAGEP

In May 2016, the United States Department of Labor Occupational Safety and Health Administration (OSHA) released an interpretation letter with the subject of RAGAGEP in Process Safety Management Enforcement to further clarify the RAGAGEP requirements of Process Safety Management (PSM) Standard 29 CFR 1910.119. In addition to clarifying requirements for use of RAGAGEP, this letter also provides examples of what can be considered RAGAGEP, including widely adopted codes, consensus documents, non-consensus documents, and internal standards [1].

Benefits of Internal Standards

As mentioned previously, several different sources can be considered RAGAGEP. While each source has its own benefits, one of the key benefits of internal standards is the ability to account for a facility’s and/or organization’s specific process, environment, and history. OSHA’s RAGAGEP in Process Safety Management Enforcement expands upon this further through the examples as quoted directly below:

  • Translating the requirements of published RAGAGEP into detailed corporate or facility implementation programs and/or procedures.
  • Setting design, maintenance, inspection, and testing requirements for unique equipment for which no other RAGAGEP exists.
  • Supplementing or augmenting RAGAGEP selected by the employer that only partially or inadequately addresses the employer’s equipment.
  • Controlling hazards more effectively than the available codes and consensus and/or non-consensus documents when deemed necessary by the employer’s PSM program.
  • Addressing hazards when the codes and consensus and/or non-consensus documents used for existing equipment are outdated and no longer describe good engineering practice [1].

Through capturing information, such as the above in an internal standards program, companies and sites can minimize in-service equipment failures, reduce front-end design efforts, create a consistent set of engineering standards for capital projects, and create a resource for the next generation. There are three critical components of a useful and well-managed program that allow engineers of all levels to learn and contribute: customization, accessibility, and the management system.

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