RAGAGEP 101

Lisa A. Long, James R. Lay, Michael L. Marshall, and Jeffrey J. Wanko

US Occupational Safety and Health Administration, 200 Constitution Avenue NW, Washington, DC 20037; [email protected]
(for correspondence)
Published online 6 November 2013 in Wiley Online Library (wileyonlinelibrary.com). DOI 10.1002/prs.11637
Recognized and generally accepted good engineering
practices (RAGAGEPs) play an important role in the Occupa-
tional Safety and Health Administrations Process Safety
Management standard (29 CFR 1910.119). Since 2007,
OSHA issued numerous RAGAGEP-related citations under
the Petroleum Renery Process Safety Management and PSM
Covered Chemical Facility National Emphasis Programs.
Even though the PSM standard became effective over 20
years ago, noncompliance with PSMs RAGAGEP require-
ments remains an issue. This article reviews RAGAGEP basics
from OSHAs perspective, using examples from national
emphasis program inspections to illustrate common RAGA-
GEP compliance problems. VC
2013 American Institute of Chemical
Engineers Process Saf Prog 33: 156161, 2014
Keywords: recognized and generally accepted good engi-
neering practice; RAGAGEP; OSHA; process safety manage-
ment; PSM; consensus codes and standards
INTRODUCTION
Good engineering practice (GEP) has always been part of
the foundation of safe operations in the chemical industry.
GEP is a part of all aspects of chemical processing including
the design of equipment, the overall process, and the man-
machine interface.
This article on recognized and generally accepted good
engineering practice (RAGAGEP):
Provides background information;
Describes how RAGAGEP evolved from early industry
descriptions, the Process Safety Management (PSM) pro-
mulgation process, Occupational Safety and Health
Administration (OSHA) interpretations, and later industry
publications;
Illustrates how other federal agencies use GEP and
RAGAGEP;
Describes OSHAs enforcement of RAGAGEP in the Petro-
leum Renery Process Safety Management National
Emphasis Program (Renery NEP) and Process Safety
Management Covered Chemical Facility National Emphasis
Program (ChemNEP);
Documents examples of OSHA citations related to RAGA-
GEP; and
Provides incidents in which RAGAGEP noncompliance
was a causal factor.
BACKGROUND
Prior to the enactment of OSHAs Process Safety Manage-
ment of Highly Hazardous Chemicals Standard (PSM) [1],
OSHA primarily enforced GEP through specic consensus
standards incorporated by reference into existing OSHA
standards. For example, OSHAs 29 CFR 1910.106 standard,
Flammable and Combustible Liquids, incorporates the Ameri-
can Society of Mechanical Engineers (ASME) Boiler and Pres-
sure Vessel Code, Section VIII1968.
However, when OSHA issued the PSM standard in 1992, it
used a different strategy to enforce GEP. Notably, the PSM
standard does not incorporate any GEP. Rather, the PSM
standard includes nonspecic requirements that employers
comply with RAGAGEP in equipment design and in inspec-
tion and testing.
A phrase that is common in the industry relating to man-
agement system performance is Say what you do and do
what you say. OSHAs PSM standard parallels this philoso-
phy in that it is largely a performance standard. The PSM
standard sets forth a management system framework upon
which employers build. The design and maintenance of the
process is an essential part of the standard in which RAGA-
GEP plays a critical role.
The PSM standard is a set of requirements for employers
with processes containing highly hazardous chemicals
(HHCs) intended to prevent releases. The PSM standard is
not prescriptive because of the number and types of indus-
tries, facilities, chemicals, and technologies covered by the
standard. Employers have latitude to develop and initiate the
required management systems in a manner that is exible
and takes into account the attributes of their covered proc-
esses and equipment while still achieving safe operations.
Specically for RAGAGEP, the PSM standard:
1. Allows employers to select appropriate RAGAGEP for
their processes;
2. Requires employers to document the RAGAGEP to which
they comply (Say what you do); and
Requires employers perform (do what you say) to the
provisions of the chosen RAGAGEP and document compli-
ance with the chosen RAGAGEP.
EARLY RAGAGEP RECOGNITION
American Institute of Chemical Engineers
One of the rst authoritative references on the use of
GEP as a guideline in the chemical processing industry was
by the American Institute of Chemical Engineers (AIChE)
Disclaimer: This paper represents the views of the authors.
Although the authors based the paper on OSHA programs, it does
not represent ofcial OSHA policy.
This article originally presented at the 9th Global Congress on Pro-
cess Safety, San Antonio, TX, 29 April to 1 May 2013.
VC
2013 American Institute of Chemical Engineers
Process Safety Progress (Vol.33, No.2) June 2014 156
Center for Chemical Process Safety (CCPS) in 1989. In the
Guidelines for Technical Management of Chemical Process
Safety [2], CCPS provided guidelines on how to use external
and internal GEP to achieve safe facilities. Some of the guid-
ance by CCPS related to GEP included:
Management of standards, codes, and regulations as a
necessary part of chemical process safety activities;
Application of external codes, standards, and regulations
to the layout, design, and operation of chemical plants
and the protection of equipment, employees, and the
public;
Means of deciding which codes, standards, and guidelines
the facility follows;
A table listing of some example external codes/regula-
tions including ASME - Boiler and Pressure Vessel Code
and Code for Pressure Piping (B31), American Petroleum
Institute (API)RP 520/521 Pressure Relieving Systems,
AIChEDesign Institute for Emergency Relief Systems
Procedure for Emergency Venting Sizing, OSHA29 CFR
1910, etc.;
Clear documentation of the chosen codes, standards and
guidelines so that those involved in design and mainte-
nance know which RAGAGEP to follow.
Means of documenting the reason for deviating from a
code or standard. The facility seeking to use an alternative
approach should demonstrate that the approach is at least
as safe as the chosen code or standard;
Development of internal standards to complement exter-
nal codes and design practices;
Developing and instituting internal standards to achieve
consistency in design, where appropriate, and to safely
operate and maintain the facilities; and
Management commitment to following all chosen RAGA-
GEP whether internally- or externally-developed.
American Petroleum Institute
In January 1990, API issued Recommended Practice (RP)
750, Management of Process Hazards [3]. RP 750 states the
following with respect to GEP:
The mechanical design information should include design
codes employed (Section 2.3.1);
The mechanical design should be consistent with the
applicable consensus codes and standards in effect at the
time the design is prepared or, in the absence of such
codes and standards, recognized and generally accepted
engineering practices (Section 2.3.2);
When the mechanical design is not consistent with appli-
cable consensus codes and standards, the deviation and
its design basis should be documented (Section 2.3.2);
When a process hazards analysis or other review reveals
that existing equipment is designed and constructed in
accordance with consensus codes, standards, or practices
that are no longer in general use, procedures should be
implemented to ensure that the equipment is t for serv-
ice (Section 2.3.2);
Facilities should establish inspection and testing programs
for critical equipment. Such programs should include test-
ing and inspection procedures in accordance with com-
mon standards and codes, such as API 510 or the API
Guide for the Inspection of Renery Equipment. (Section
8.5(a)).
OSHA Proposed PSM Rule
In 1990, OSHA issued a Notice of Proposed Rulemaking
(NPRM) for the PSM rule [4]. The NPRM proposed regula-
tions including some related to RAGAGEP, however, the
NPRM contained no background information on the genesis
or intent of the specic RAGAGEP requirements. The NPRM
contained the following language on RAGAGEP:
1910.119(d)(3)(i)(F)The employer shall develop and
maintain a compilation of written safety informa-
tion. . .information pertaining to the equipment in the pro-
cess shall include. . ..Design codes employed;
1910.119(d)(3)(ii)The employer shall document that
equipment complies with applicable codes and standards,
such as those published by the ASME, API, AIChE, ANSI,
ASTM, and NFPA, where they exist; or RAGAGEPs;
1910.119(d)(3)(iii)For existing equipment designed and
constructed in accordance with codes, standards, or prac-
tices that are no longer in general use, the employer shall
determine and document that the equipment is designed,
maintained, inspected, tested, and operating in a safe
manner;
1910.119(j)(3)(ii)Inspection and testing procedures shall
follow applicable codes and standards, such as those pub-
lished by ASME, API, AIChE, ANSI, ASTM, and NFPA,
where they exist; or RAGAGEPs; and
1910.119(j)(3)(iii)The frequency of inspections and tests
of process equipment shall be consistent with applicable
codes and standards, or, more frequently if determined to
be necessary by prior operating experience.
OSHA FINAL RULE ON PSM AND RAGAGEP
In 1992, OSHA promulgated its PSM regulation containing
some, but not all, of the RAGAGEP provisions listed in the
NPRM. The preamble to the PSM rule explains that the
phrase recognized and generally accepted good engineering
practices included both appropriate internal standards and
applicable published codes and standards.
The preamble to the nal PSM standard [5] describes how
and why RAGAGEP became part of the regulation:
(57 FR 6375) As part of the process safety information
the employer is required to document that the process
equipment being used complies with applicable consen-
sus codes and standards, where they exist; or must be
consistent with recognized and generally accepted engi-
neering practices.
OSHA modied the paragraph 1910.119(d)(3)(ii) from the
NPRM by eliminating the specic list of codes and stand-
ards producing organizations.
OSHA stated that the discussion in paragraph (j), Mechan-
ical Integrity, section of the preamble describes the rea-
sons for the change from the specic list of required
codes and standards.
(57 FR 63906391) OSHA explained the intent of pro-
posed paragraph (j)(3)(ii) was an effort to assure that
inspections and tests are performed properly.
Many commenters to the NPRM, though, objected to
OSHAs inclusion of a list of consensus documents in the
regulation. While OSHA believed the lists in the proposed
(d)(3)(ii) and (j)(3)(ii) were not exhaustive nor attempts at
incorporation by reference, OSHA published the nal rule
without lists.
The following RAGAGEP rules show the nal text of the
existing RAGAGEP standards. Bolded text represents lan-
guage added to the nal standards following the comment
period and the struck-through portion represents language
removed:
1910.119(d)(3)(i)(F)The employer shall develop and
maintain a compilation of written safety informa-
tion. . .information pertaining to the equipment in the
Process Safety Progress (Vol.33, No.2) Published on behalf of the AIChE DOI 10.1002/prs June 2014 157
process shall include. . ..Design codes and standards
employed;
1910.119(d)(3)(ii)The employer shall document that
equipment complies with RAGAGEPs.
1910.119(d)(3)(iii)For existing equipment designed and
constructed in accordance with codes, standards, or prac-
tices that are no longer in general use, the employer shall
determine and document that the equipment is designed,
maintained, inspected, tested, and operating in a safe
manner;
1910.119(j)(4)(ii)Inspection and testing procedures shall
follow RAGAGEPs. And
1910.119(j)(4)(iii)The frequency of inspections and tests
of process equipment shall be consistent with applicable
manufacturers recommendations and GEPs, and
more frequently if determined to be necessary by prior
operating experience.
Appendix C to the PSM Final Rule
Appendix C to the PSM Final Rule, Compliance Guide-
lines and Recommendations for Process Safety Management
(Non-Mandatory), contains information for the regulated
community related to RAGAGEP. Appendix C states the fol-
lowing with respect to the design of equipment:
The information pertaining to process equipment design
must be documented. In other words, what were the codes
and standards relied on to establish GEP. These codes and
standards are published by such organizations as the Ameri-
can Society of Mechanical Engineers, API, American National
Standards Institute, National Fire Protection Association,
American Society for Testing and Materials, National Board
of Boiler and Pressure Vessel Inspectors, National Association
of Corrosion Engineers, American Society of Exchange Manu-
facturers Association, and model building code groups.
In addition, various engineering societies issue technical
reports which impact process design. For example, the
AIChE has published technical reports on topics such as two
phase ow for venting devices. This type of technically rec-
ognized report would constitute GEP.
Note, the codes and standards listed above are examples
and not mandatorythe employer selects the appropriate
RAGAGEP with which to comply.
The following excerpt from Appendix C discusses RAGA-
GEP as it relates to mechanical integrity inspections and tests:
Also, applicable codes and standards such as the National
Board Inspection Code, or those from the American Society
for Testing and Material, API, National Fire Protection Associ-
ation, American National Standards Institute, American Soci-
ety of Mechanical Engineers, and other groups, provide
information to help establish an effective testing and inspec-
tion frequency, as well as appropriate methodologies.
The applicable codes and standards provide criteria for
external inspections for such items as foundation and sup-
ports, anchor bolts, concrete or steel supports, guy wires,
nozzles and sprinklers, pipe hangers, grounding connections,
protective coatings and insulation, and external metal surfa-
ces of piping and vessels, etc. These codes and standards
also provide information on methodologies for internal
inspection, and a frequency formula based on the corrosion
rate of the materials of construction. Also, erosion both inter-
nal and external needs to be considered along with corro-
sion effects for piping and valves. Where the corrosion rate
is not known, a maximum inspection frequency is recom-
mended, and methods of developing the corrosion rate are
available in the codes. Internal inspections need to cover
items such as vessel shell, bottom and head; metallic linings;
nonmetallic linings; thickness measurements for vessels and
piping; inspection for erosion, corrosion, cracking and
bulges; internal equipment like trays, bafes, sensors and
screens for erosion, corrosion or cracking and other decien-
cies. Some of these inspections may be performed by state
or local government inspectors under state and local statutes.
However, each employer needs to develop procedures to
ensure that tests and inspections are conducted properly and
that consistency is maintained even where different employ-
ees may be involved. Appropriate training is to be provided
to maintenance personnel to ensure that they understand the
preventive maintenance program procedures, safe practices,
and the proper use and application of special equipment or
unique tools that may be required. This training is part of
the overall training program called for in the standard.
FURTHER GUIDANCE ON RAGAGEP
Center for Chemical Process Safety
In 2006, CCPS published, Guidelines for Mechanical
Integrity Systems [6] which discusses RAGAGEP extensively
what it is, how it is used, application to different classes of
equipment, design, fabrication, construction/installation,
inspection, testing, and maintenance activities. The text con-
tains the following information on RAGAGEP:
A description of RAGAGEP with many examples;
Facility-develop internal standards provided by the manu-
facturer or licensor of a process and often these are based
on RAGAGEP;
Recognition that to effectively use RAGAGEP, facility man-
agement must determine which practices are available
and then assess the applicability of each practice to their
facility; and
Several chapters that address the applicability and use of
RAGAGEP for detailed operations, for example, vessel
design and fabrications, in-service piping inspections,
RAGAGEP for instrumentation and controls, RAGAGEP for
prime movers, etc.
Incorporation of Consensus Standards
In federal regulation, use of the terms recognized and gen-
erally accepted good engineering practices and RAGAGEP ori-
ginated with OSHA. However, the Federal government has
long encouraged the use of voluntary consensus standards in
regulatory affairs. The National Technology Transfer and
Advancement Act of 1995, as interpreted by the Ofce of
Management and Budgets (OMBs) Circular Number A-119
[7], instructs agencies to use voluntary consensus standards in
lieu of government-unique standards except where inconsis-
tent with law or otherwise impractical. In addition, OMB A-
119 states that many voluntary consensus standards are
appropriate or adaptable for the governments purposes.
OMB A-119 denes standards and technical standards
as:
1. Common and repeated use of rules, conditions, guide-
lines or characteristics for products or related processes
and production methods, and related management sys-
tems practices.
2. The denition of terms; classication of components;
delineation of procedures; specication of dimensions,
materials, performance, designs, or operations; measure-
ment of quality and quantity in describing materials,
processes, products, systems, services, or practices; test
methods and sampling procedures; or descriptions of t
and measurements.
OMB further denes voluntary consensus standards as
standards developed or adopted by voluntary consensus
standards bodies, both domestic and international. These
DOI 10.1002/prs Process Safety Progress (Vol.33, No.2) 158 June 2014 Published on behalf of the AIChE
bodies must have attributes including openness, balance of
interest, due process, an appeals process, and consensus,
dened as general agreement, but not necessarily unanimity,
with a process for attempting to resolve objections by inter-
ested parties. Circular A-119 also denes other types of
standards as non-consensus standards, industry standards,
Company standards, or de facto standards developed in
the private sector but without the full consensus process.
Government agencies regulating HHCs use voluntary con-
sensus standards in a variety of ways. For example, Section
6(a) of the Occupational Safety and Health Act of 1970 [8]
gave the nascent OSHA a two-year window in which to by
rule promulgate as an occupational safety or health standard
any national consensus standard, and any established Federal
standard. . . The 6(a) provision enabled OSHA to quickly
establish a basic suite of protective standards. National con-
sensus standards incorporated by reference into regulations
under this provision of the OSH act are listed in 29 CFR
1910.6 Incorporation by reference. Examples include the
ASME Boiler and Pressure Vessel Code, Section VIII Unred
Pressure Vessels, Including Addenda (1969), incorporation by
reference approved for OSHA standards 1910.261, 1910.
262, and 1910.263(i)(24)(ii); and API 650 (1966) Welded Steel
Tanks for Oil Storage, 3rd Ed., incorporation by reference
approved for 1910.106(b)(1)(iii)(a)(2). Since OSHAs incor-
poration by reference provision expired in 1974, the agency
has followed the rule making process referenced in section
6(b) of the OSHA Act, including for updating references to
more recent versions of national consensus standards. Incor-
poration of consensus standards by reference has benets to
both OSHA and the regulated community. However, OSHA
must incorporate a specic version of a standard. When the
consensus standard is updated, OSHAs incorporated stand-
ard becomes dated and can only be updated through the
rulemaking process. Commenters on OSHAs ANPRM real-
ized this, and this resulted in a different approach, the intro-
duction of the RAGAGEP concept.
OSHA RAGAGEP ENFORCEMENT
OSHA RAGAGEP Policy
In the past, OSHA issued enforcement policy related to
RAGAGEP. The rst milestone enforcement policy related to
RAGAGEP was a 2000 OSHA Letter of Interpretation (LOI) to
the Instrument Society of America [9]. In this LOI, OSHA
stated the following regarding the agencys RAGAGEP policy:
1910.119(d)(3)(i)(F) requires an employer to document
which design codes and standards are used for SIS as
well as all covered equipment;
1910.119(d)(3)(ii) requires an employer to document that
SIS comply with RAGAGEP;
1910.119(j)(4) requires an employer to conduct inspection
and testing on process equipment, including SIS, in
accordance with RAGAGEP;
If an employer documents compliance with ISA S84.01 for
SIS in accordance with 1910.119(d)(3)(i)(F) and it meets all
S84.01 and other OSHA PSM requirements related to SIS,
OSHA considers the employer in compliance with PSM
requirements for SIS.
OSHA issued a second important RAGAGEP enforcement
policy LOI in 2010 [10]. In this LOI related to blast resistant
structures, OSHA reiterated its policy for enforcing the
RAGAGEP sections of the PSM standard.
OSHA RAGAGEP Enforcement
Because Process Safety information and, specically, com-
pliance with RAGAGEP is such an important part of a strong
PSM program, OSHA emphasizes this in both the Renery and
Chem NEPs. Both NEPs rely on focused questions and compli-
ance guidance that Compliance Ofcers can ask to help assess
compliance with the standard. The Renery NEP contains both
static and dynamic (or changing) questions. OSHA published
the static questions in the NEP while the dynamic questions
changed periodically and limited to distribution within OSHA.
The Renery NEP static questions focus on the following
areas with respect to RAGAGEP:
Relief Systems/Blowdowns
Does the PSI contain information on the RAGAGEP
used?
Does the PSI contain the RAGAGEPs required design
parameters?
Do the relief valves comply with the RAGAGEP?
Are intervening valves appropriate and adequately
controlled?
Do the valves/blowdowns relieve to a safe location?
Are blowdown alarm systems in accordance with
RAGAGEP?
Is blowdown quench water system in accordance with
RAGAGEP?
Does the relief testing program comply with RAGAGEP?
Frequency
Personnel qualications
Testing procedures
Testing blowdown alarms
Facility Siting
Pressure vessels/Piping
Does the PSI contain information on the RAGAGEP?
Are the safeguards properly designed?
Does the testing and inspection comply with RAGAGEP
Bonded liners
Thickness measurement locations
Corrosion under insulation
Testing frequency
Personnel qualications
Testing basis
Injection points
Appropriate testing locations
It is important to note that OSHA also uses RAGAGEP
compliance questions in it dynamic list of inspection priority
items in both its Renery and Chem NEPs.
OSHA analyzed citation data from the Renery and Chem
NEPs to determine the most frequently cited standards and
any trends. In both enforcement efforts, the most frequently
cited PSM sub-element is 1910.119(d)(3)(ii)the requirement
that employers document that equipment complies with
RAGAGEP. Of these citations, most common areas cited
involved valves and facility siting.
The following list outlines some of the valve-related
issues cited while enforcing the Renery NEP:
Valves between pressure vessel and relief device not
locked open or controlled.
Relief device appropriate back pressure not maintained.
Relief device inlet line pressure drop or chattering
problems.
Relief devices not installed on pressure vessels.
Relief devices not appropriately sized for the
circumstances.
Valves inaccessible.
Valves inoperable.
The following list outlines to two most frequent concerns
regarding facility siting:
Facilities not compliant with RAGAGEP chosen by the
facility, and
Process Safety Progress (Vol.33, No.2) Published on behalf of the AIChE DOI 10.1002/prs June 2014 159
Structures either unprotected by adequate separation or
building construction from consequences of HHC release
such as re, explosion, or toxic releases.
In the case of facility siting, citations often reference mul-
tiple on-site structures including control rooms and other
buildings. In many cases, siting studies identied issues that
the facility had not resolved in a timely manner.
OSHA also commonly cites the failure to document
RAGAGEP in Chemical NEP inspections. However, due to
the larger variety of facility types inspected, it is difcult to
determine trends. The following list is a sample of RAGAGEP
violations found during Chemical NEP inspections:
Safety interlocks do not follow RAGAGEP
RAGAGEP not documented for equipment (glass lined
vessels, piping, rupture disks, chemical hoses, pumps)
RAGAGEP not documented for ventilation systems design
Ammonia system labeling not in accordance with
RAGAGEP
Chlorine alarm systems not designed in accordance with
RAGAGEP
Piping supported did not follow RAGAGEP
Corrosion rates not calculated in accordance with
RAGAGEP
Chlorine did not have shut-off valves in accordance with
RAGAGEP
Relief devices not designed in accordance with RAGAGEP
PSM explicitly requires employers to document that the
equipment complies with RAGAGEP at the time the process
was originally built. However, employers should stay abreast
of current engineering codes, standards, and practices.
Changes in codes, standards, and practices often result when
industry has discovered new hazards or new means of haz-
ard control. If a the PHA team nds the process design does
not adequately protect against a newly discovered or newly
recognized hazard, employers should consider compliance
with a more recent code or additional safeguards to ensure
employees are protected.
CHEMICAL PROCESS SAFETY INCIDENTS AND RAGAGEP
Process safety incidents in the chemical and rening
industries occur for many reasons. Investigators nd multiple
broken barriers that result in a process safety incident. Bar-
riers such as engineering and administrative controls often
play a role in the prevention of chemical process incidents.
Barrier design, operation, and maintenance are frequently
based on RAGAGEP.
Highlights of incidents reveal many employer failures
regarding RAGAGEP allowing incident trajectories to con-
tinue to harmful outcomes.
Bellwood, IllinoisJune 14, 2006
The incident occurred when a mixture of ammable
liquids boiled in an open-top kettle. Vapors escaped the ket-
tle and owed into the processing room and into an adjoin-
ing warehouse/general purpose room where it ignited. The
ash re and deagration killed one and injured two.
The facility installed the chemical processing area in
direct communication with the general use area not in
accordance with NFPA 30. In addition, the ventilation system
was designed with only overhead point pick-up and not
general ventilation with oor sweeps.
Middleton, MassachusettsMarch 13, 2011
The release of acetone vapor into a congested workspace
caused a deagration that nearly destroyed the building. The
ventilation system design was not designed to sweep or
remove ammable vapors from the room. The facility did
not use NFPA 30 in its ventilation system design. The inad-
equately designed ventilation allowed ammable vapors to
accumulate.
Houston, TexasApril 12, 2004
The employer modied a large pressure vessel for its
operation. The modication involved cutting and subsequent
replacing a large coupon in the vessel wall. The modication
did not follow RAGAGEP for performing welding on a pres-
sure vessel. After the facility placed the modied vessel into
service, it failed at the welded coupon, ejected its contents,
rocketed into a neighboring building, and caused a large
re.
Illiopolis, IllinoisApril 23, 2004
An explosion and re killed ve and injured three at this
polyvinyl chloride facility. Many factors combined to cause a
release of vinyl chloride monomer into the congested work-
space. However, the facility had not designed and main-
tained its safety interlocks in accordance with RAGAGEP as
they were easily disabled or bypassed. When needed to pre-
vent the release, the interlock was bypassed and the release
occurred.
Two of the most basic backbones of any process safety
program are to design equipment in accordance with RAGA-
GEP and to maintain, inspect, and test equipment in accord-
ance with RAGAGEP. Given these two fundamental tenets of
process safety, there is little doubt that contributing to most
incidents are failures to adhere to these requirements.
CONCLUSION
The RAGAGEP concept as used by OSHA comprises hun-
dreds of industry-published codes and standards and, possi-
bly, many thousands of internally-produced practices and
protocols. When promulgated, the PSM standard made man-
datory that facilities adopt code and standards published for
their industry or produce internal standards that meet similar
requirements. The management system that OSHA envi-
sioned with the PSM standard is no different from any qual-
ity cycle (plan-do-check-act) and RAGAGEP plays a critical
role.
Because OSHA is not in a position to be expert in any
industry, use of RAGAGEP is critical to the success of a per-
formance standard such as PSM. Using the collective wisdom
and experience of industry experts, RAGAGEP helps achieve
safe operations throughout industries using HHCs.
LITERATURE CITED
1. Process Safety Management of Highly Hazardous Chemi-
cals, 29 CFR 1910.119, 57 FR 6356, February 24, 1992.
2. Center for Chemical Process Safety, Guidelines for Tech-
nical Management of Chemical Process Safety, Center for
Chemical Process Safety, 1989, pp 123127.
3. Management of Process Hazards, American Petroleum
Institute Recommended Practice 750, 1990.
4. 55 FR 2915029173, Occupational Safety and Health
Administration, July 27, 1990.
5. 57 FR 6356, Preamble to OSHA PSM Final Rule, February
24, 1992.
6. Center for Chemical Process Safety, Guidelines for
Mechanical Integrity Systems, Center for Chemical Pro-
cess Safety, 2006.
7. Federal Participation in the Development and Use of Vol-
untary Consensus Standards and in Conformity Assess-
ment Activities, OMB Circular A-119, Revised on
February 10, 1998, available at: http://www.whitehou-
se.gov/omb/circulars_a119/, accessed on February 13,
2013.
8. Occupational Safety and Health Act of 1970, 29 USC 651
678, December 1970.
DOI 10.1002/prs Process Safety Progress (Vol.33, No.2) 160 June 2014 Published on behalf of the AIChE
9. Compliance with PSM and ANSI/ISA-S84.01 for safety
instrumented systems, Occupation Safety and Health
Administration Letter of Interpretation, available at:
http://www.osha.gov/pls/oshaweb/owadisp.show_
document?p_table5INTERPRETATIONS&p_id523722,
accessed on March 23, 2000.
10. Applicability of the PSM Standards Mechanical Integrity
Requirements to Renery Structures, Occupational
Safety and Health Administration Letter of Interpretation,
available at: http://www.osha.gov/pls/oshaweb/
owadisp.show_document?p_table5INTERPRETATIO-
NS&p_id527443, accessed on February 1, 2010.
Process Safety Progress (Vol.33, No.2) Published on behalf of the AIChE DOI 10.1002/prs June 2014 161