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On June 5, 2015, the agency issued an enforcement memorandum on “recognized and generally accepted good engineering practices (RAGAGEP) in Process Safety Management Enforcement.” The memorandum will affect all facilities that fall under OSHA’s Refinery NEP, as well as state equivalents to the Refinery NEP (CPL 03-00-010). Keep reading to find out what the regulation means for those facilities.
Defining RAGAGEP
The PSM standard does not define RAGAGEP, even though it uses or implies the term in three places:
- 29 CFR 1910.119(d)(3)(ii) requires employers to document that all equipment in PSM-covered processes complies with RAGAGEP;
- 29 CFR 1910.119(j)(4)(ii) requires inspections and tests performed on process equipment subject to the standard’s mechanical integrity requirements to be completed in accordance with RAGAGEP; and
- 29 CFR 1910.119(j)(4)(iii): requires that inspections and tests be conducted on a schedule that follows manufacturer’s recommendations and good engineering practice, and more frequently if indicated by operating experience.
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In addition, 29 CFR 1910.119(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.
To define the term, OSHA’s Refinery NEP references the definition found in the Center for Chemical Process Safety’s (CCPS) Guidelines for Mechanical Integrity Systems. “‘Recognized And Generally Accepted Good Engineering Practices’ are the basis for engineering, operation, or maintenance activities and are themselves based on established codes, standards, published technical reports, or recommended practices or similar documents. RAGAGEP detail generally approved ways to perform specific engineering, inspection, or mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or servicing a relief valve.”
As used in the PSM standard, RAGAGEP apply to process equipment design, installation, operation, and maintenance; inspection and test practices; and inspection and test frequencies. RAGAGEP must be both “recognized and generally accepted” and “good engineering” practices.
RAGAGEP Sources
The PSM standard allows employers to select the RAGAGEP they apply in their covered processes; employers will need to make sure that their selected RAGAGEP meet OSHA’s criteria for authoritative sources. When inspectors assess how well a facility’s procedures align with RAGAGEP, they will look for applicable RAGAGEP that include:
- Published and widely adopted codes. Many state and municipal codes incorporate or adopt codes such as the National Fire Protection Association (NFPA) 101 Life Safety and NFPA 70 National Electric codes. These codes are generally accepted as RAGAGEP.
- Published consensus documents. The American National Standards Institute (ANSI) sets due process requirements for national standards; standards that meet those requirements are considered RAGAGEP. Standards published by the American Society of Mechanical Engineers and the International Institute of Ammonia Refrigeration, for example, meet these requirements.
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- Published nonconsensus documents. Some published nonconsensus documents don’t conform to ANSI’s due process requirements—but may be widely accepted as good practices in a given industry. Examples include the Chlorine Institute’s pamphlets on chlorine and sodium hypochlorite (bleach) safety and many CCPS guideline books that deal with equipment-specific topics. Peer-reviewed technical articles addressing specific hazards may also fall into this category.
- Applicable manufacturer’s recommendations. The operating instructions and manuals that come with a piece of equipment may include maintenance schedules and other information that would be considered RAGAGEP.
- Internal standards. Employers may develop internal standards for use within their facilities. Employers’ internal standards must either meet or exceed the protective requirements of published RAGAGEP, where such RAGAGEP exist.
Tomorrow, we’ll look at some specifics of how OSHA inspectors evaluate and apply RAGAGEP guidance.