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Dates: May 23, 2017 - May 26, 2017
Recognized And Generally Accepted Good Engineering Practices (RAGAGEP) are an essential part of OSHA's process safety management standard (29 CFR 1910.119) and are the basis for safe and reliable inspection, maintenance, operation, and engineering activities. RAGAGEP is based on established industry codes, standards, recommended practices, technical reports, or similar documents.
OSHA recognizes that while the PSM standard does not define RAGAGEP and employers may select the RAGAGEP that will apply to their covered processes, there are several consensus standards that are widely adopted by federal, state and municipal jurisdictions and are generally accepted by OSHA as RAGAGEP. OSHA also recognizes that non-consensus engineering documents or peer-reviewed technical articles addressing specific hazards may serve as RAGAGEP when published standards are not available or are not adequate to address specific hazards. However, the adequacy of these materials must be determined on a case-by-case basis.
Furthermore, OSHA concludes that even an employer’s internally developed standards may serve as RAGAGEP for use within a facility when no published RAGAGEP exists or when the RAGAGEP must be supplemented in order to better control or address a hazard. In order for internally developed standards to serve as RAGAGEP, OSHA now makes clear that the internally developed standards must either meet or exceed the protective requirements of the published RAGAGEP when it exists.
Because the meaning of SHALL versus SHOULD is often a point of contention, employers should always carefully review RAGAGEP language to determine whether the provisions are required (i.e., “shall” or “must”) or merely one acceptable approach (i.e., “should”).
OSHA has issued guidance on the enforcement of the Process Safety Management (PSM) standard's RAGAGEP requirements. The memorandum provides the most detailed information on how OSHA will handle PSM inspections with respect to the RAGAGEP requirements and what it considers RAGAGEP, and it includes 16 detailed enforcement considerations that inspectors will evaluate when reviewing an employer’s compliance. A copy of OSHA's guidance can be found at https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=29414.
September/October 2015 Inspectioneering Journal
If we could measure, understand, mitigate, and most importantly, control corrosion, we can do a better job of keeping the product in the pipes. To accomplish this task, we needed to know what is causing the corrosion and how to control it.
A new memorandum released by OSHA provides a list of 16 enforcement considerations that will be considered by an inspector when evaluating whether an employer is meeting the RAGAGEP requirements under the PSM standard. Here are 8 tips for addressing OSHA's new enforcement guidance.
November/December 2014 Inspectioneering Journal
By Marc McConnell, P.E. at Versa Integrity Group, Josh Yoakam at Holly Refining and Marketing - Tulsa, LLC, and Jeannie Beth Richey at Sasol North America, Inc.
The role of an API inspector is rapidly changing. Necessary skills for success have transformed as technology, standardization, and regulations have become part of the way of life.