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PT Notes

OSHA RFI - Defining and Evaluating Updates to RAGAGEP

PT Notes is a series of topical technical notes provided periodically by Primatech for your benefit. Please feel free to provide feedback.

On December 3, 2013, the U.S. Occupational Safety and Health Administration (OSHA) announced a request for information (RFI) seeking public comment on potential revisions to its Process Safety Management (PSM) standard. Multiple issues were addressed in the RFI.

One issue deals with clarifying the PSM standard by adding a definition for RAGAGEP. The term appears in the requirements for process safety information and mechanical integrity. However, the standard does not define the term.

OSHA is considering the adoption of a definition used by the Center for Chemical Process Safety: RAGAGEP are the basis for engineering, operation, or maintenance activities and are themselves based on established codes, standards, published technical reports or recommended practices (RP) or similar documents. RAGAGEPs 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. This definition is consistent with OSHA's intent when it promulgated the PSM standard.

OSHA has posed these questions on this issue in the RFI:

  1. What does your facility use as a definition for RAGAGEP?
  2. Would adding a definition for RAGAGEP to the PSM standard improve understanding of PSM requirements and prevent worker injuries and fatalities? If so, what specific definition for RAGAGEP should OSHA add to the PSM standard? What would be the economic impacts of adding such a definition? Are there any special circumstances involving small entities that OSHA should consider with respect to this option?
  3. What criteria does your facility use to develop appropriate internal standards? For instance, if there is an applicable consensus standard, what steps do you take to ensure that your internal standards are at least as protective as the applicable standard?

Another issue deals with amending the PSM standard to require evaluation of updates to applicable Recognized and Generally Acceptable Good Engineering Practices (RAGAGEP) under the process safety information element of the standard.

There is a requirement in the standard that the employer document that covered equipment complies with RAGAGEP and another requirement that the employer shall determine and document that for existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use the equipment is designed, maintained, inspected, tested, and operated in a safe manner. However, the standard does not require employers to evaluate updates to applicable RAGAGEP or to examine new RAGAGEP after evaluating and documenting compliance with these requirements.

The practices that constitute RAGAGEP under the PSM standard are constantly changing. Thus, evaluating updates to applicable RAGAGEP would ensure that a facility's PSM program is based on the most up to date and accurate information available.

OSHA has posed these questions on this issue in the RFI:

  1. From what sources (e.g., codes, standards, published technical reports, consensus standards) does your facility select applicable RAGAGEP for operations covered under the PSM standard?
  2. Does your facility evaluate updates to its selected RAGAGEP? If so, how does your facility monitor any updates, and how often do you evaluate them?
  3. Please provide any data or information on workplace accidents, near misses, or other safety related incidents involving failure to evaluate updates to applicable RAGAGEP for PSM covered operations.
  4. What would be an appropriate time period in which to conduct this evaluation? Would such a requirement be more appropriate in another paragraph of the PSM standard? For example, should such a requirement become part of the requirements for process hazard analysis revalidation?
  5. Would requiring employers to evaluate updates to applicable RAGAGEP prevent worker injuries and fatalities? Is there another approach that can be used to ensure the incorporation of RAGAGEP into facility operations that is tangible and documentable? What would be the economic impacts of this requirement? Are there any special circumstances involving small entities that OSHA should consider with respect to this option?

For more information, you can contact Primatech or click on these links:

RAGAGEP 101

RAGAGEP beyond regulation: Good engineering practices for the design and operation of plants

Federal Register notice

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