PSM RAGAGEP—Be Wary of Internal Standards

The Occupational Safety and Health Administration (OSHA) recently updated its guidance concerning the process safety management (PSM) recommended and generally accepted good engineering practices (RAGAGEP) letter of interpretation. Yesterday we reviewed the general provisions of the guidance. Today we will take a look at what OSHA has to say about using internal standards as RAGAGEP.

OSHA includes internal standards that employers may develop for their facilities as an example of RAGAGEP. However, internally developed standards must still represent recognized and generally accepted good engineering practices.

If you choose to develop your own internal standards as RAGAGEP for processes at your facility, you might want to consider how strict you make them.

It’s possible that stricter standards may be needed to adequately control hazards because of the unique characteristics of a process at your facility. Be wary, though, when developing stricter internal standards. Here’s why.

When the Inspector Comes Knocking

OSHA has identified internal standards for RAGAGEP as a possible enforcement issue.

While your internal standards may be stricter than other relevant sources of RAGAGEP, you will be held accountable to them. In all cases you must document that your equipment complies with RAGAGEP.

Even if you meet the requirements of other applicable sources of RAGAGEP, but you fail to comply with your own stricter internal requirements, OSHA could potentially cite you under other PSM provisions. For instance:

  • If you fail to follow stricter internal inspection and test (I&T) procedures, inspectors may cite you under 29 CFR 1910.119(j)(2) for failure to implement your written I&T procedures.
  • If your process equipment is outside acceptable limits defined in your process safety information required by 29 CFR 1910.119(d), inspectors may cite you under 29 CFR 1910.119(j)(5) for equipment deficiencies.
  • You may have additional or stricter equipment safeguards based on the findings and recommendations from process hazard analyses, incident investigations, or management of change procedures. Inspectors may cite you for failure to implement or complete documented actions-to-be-taken under the relevant section of the PSM standard.

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