Navigating the RAGAGEP Maze Highlights

Compliance with the Process Safety Management (PSM) Standard is challenging for even the most sophisticated operators because of the broad scope and technical nature of the 14 PSM elements ― specifically PSI, process hazard analysis, and mechanical integrity ― that have resulted in the majority of OSHA citations under the petroleum refinery (>50%) and chemical (>60%) PSM National Emphasis Programs.

In June 2015, OSHA issued an enforcement memorandum on recognized and generally accepted good engineering practices (RAGAGEP) in Process Safety Management Enforcement. As used in the PSM standard, RAGAGEP applies to process equipment design, installation, operation, and maintenance; inspection and test practices; and inspection and test frequencies. Then in May 2016, OSHA published a revised RAGAGEP enforcement policy with several changes to the 2015 memorandum made, to resolve and settle legal industry challenges.

This publication gives a brief overview of when non-compliance situations can become a legal violation for a facility under the PSM Standard. Compare and contrast the 2015 and 2016 OSHA memorandums to learn more about their requirements. Also, find out what risk-reduction steps an organization can take in the interim to stay in compliance with OSHA regulations.

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