Guidance Clarifies Enforcement Considerations for OSHA’s PSM Standard
An OSHA memo released in June provides guidance on enforcement of the “recognized and generally accepted good engineering practices” (RAGAGEP) requirements of the agency’s Process Safety Management (PSM) Standard. The new guidance addresses the use of internal employer documents as RAGAGEP and how to interpret “shall” and “should” language in published codes, standards, technical reports, recommended practices, and similar documents. OSHA details enforcement considerations for the agency’s certified safety and health officials in evaluating employers’ compliance with RAGAGEP requirements, including guidance on when citations may be issued. The memo also lists the definition for RAGAGEP, a term that is not defined in OSHA’s PSM standard: “‘Recognized And Generally Accepted Good Engineering Practices’ (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. 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.” The definition comes from the Center for Chemical Process Safety’s (CCPS) Guidelines for Mechanical Integrity Systems. According to OSHA, RAGAGEP apply to process equipment design, installation, operation, and maintenance; inspection and test practices; and inspection and test frequencies, and must be both “recognized and generally accepted” and “good engineering” practices.