Over the years, RAGAGEP has been embedded into OSHA’s PSM standard, 29 CFR 1910.119, evolving to ensure that industries adhere to the latest and greatest engineering practices. Initially published on February 24, 1992, OSHA’s PSM standard has undergone several updates to enhance its applicability and effectiveness. In May 2016, OSHA issued the guidance document “RAGAGEP in Process Safety Management Enforcement” providing detailed explanations on how RAGAGEP should be applied in the industry. In 2022, OSHA published proposed updates to its PSM standard, emphasizing the critical role of RAGAGEP in process safety programs. These updates highlight the necessity of adhering to the latest safety standards and integrating RAGAGEP into various aspects of process safety management.

In one of the proposed definitions (2022), Recognized and Generally Accepted Good Engineering Practices (RAGAGEP), shall be defined by OSHA in  29 CFR 1910.119(b), as the “engineering, operation, or maintenance practices established in codes, standards, published technical reports, or recommended practices or similar documents.” RAGAGEP highlights the importance of following proper codes and standards, and applying sound engineering judgment in situations where standards may be ambiguous or outdated. For example, a refinery might adopt the latest API standards for pressure-relieving devices, ensuring all practices are up-to-date and well-documented. These practices are essential for ensuring safe and efficient industrial operations and play a crucial role in implementing the Process Safety Management (PSM) program, particularly in elements such as Process Safety Information (PSI), Mechanical Integrity (MI), and Process Hazard Analysis (PHA). Regulatory bodies like the United States Occupational Safety & Health Administration (US OSHA), the United States Environmental Protection Agency (US EPA), and the American Chemistry Council (ACC) look to RAGAGEP to cover diverse and ever evolving safety scenarios.

Key Elements of the PSM Standard Related to the 2022 RAGAGEP Updates

Process Safety Information (PSI)

Under paragraph (d)(3)(ii): “Employers must verify that all equipment in PSM-covered processes aligns with RAGAGEP.” For instance, a chemical plant must document that its pressure relief devices conform to the latest ASME Boiler and Pressure Vessel Code standards, ensuring they are designed, maintained, and operated according to recognized best practices.

In 2022, the proposed update now requires that an evaluation of any changes applicable RAGAGEP under PSI is completed. Facilities must regularly review and integrate the latest industry standards into their systems. For example, a chemical plant might update its safety practices based on the latest update of codes and standards from key organizations publishing RAGAGEP.

Mechanical Integrity (MI)

Under paragraph (j)(4)(ii): “Inspections and tests are performed on process equipment subject to the standard’s mechanical integrity requirements in accordance with RAGAGEP.” For example, a refinery should perform regular inspections and tests on its pressure vessels as prescribed by API standards, to ensure ongoing safety and integrity.

Moreover, under paragraph (j)(4)(iii): “Inspection and test frequency follows manufacturer’s recommendations and good engineering practice, and more frequently if indicated by operating experience.” For example, rotating equipment like pumps might require more frequent inspections if past operational data indicates a higher failure rate under specific conditions, following guidance from standards like API 610 for centrifugal pumps.

Process Hazard Analysis (PHA)

The most recent EPA Risk Management Program (RMP) ruling, announced on March 1, 2024, further highlights the importance of RAGAGEP in PHAs. This ruling mandates that high-risk facilities include Safer Technology and Alternatives Analysis (STAA) in their PHAs, to assess risks, explore safer alternatives, and implement preventive measures. These facilities must also assess the risks of regulated substances, explore safer alternatives, and implement Inherently Safer Technologies and Designs (IST/ISD). Most importantly, the regulation stipulates that the latest RAGAGEP must be considered when conducting PHAs. The following section discusses how RAGAGEP must be applied on PHAs.

How to Properly Implement  RAGAGEP in PHAs

To ensure compliance with RAGAGEP, facilities can incorporate the verification of adhering to these practices into their PHA checklists systematically. Checklists, often used alongside HAZOP, are a straightforward way to apply design standards, recommended practices, and lessons learned to ensure that hazards are not overlooked. The PHA team uses these lists to systematically verify that all potential risks are considered and addressed. However, checklists tend to be general and may not be appropriate for specific situations and hazards, particularly those involving novel designs or unconventional processes (CCPS, Guidelines for Hazard Evaluation Procedures, 3rd ed., AIChE, New York, 2008, Chapters. 4.4, 17, Appendix A). The CCPS Guidelines for Engineering Design for Process Safety, 2nd ed. (AIChE, New York, 2012), provides a useful set of checklists for the following common chemical processing equipment, including past incidents, failure scenarios, design solutions, and design considerations:

  • Vessels
  • Reactors
  • Mass Transfer Equipment
  • Heat Transfer Equipment
  • Dryers
  • Fluid Transfer Equipment
  • Solid-Fluid Separators
  • Solids Handling and Processing Equipment
  • Fired Equipment
  • Piping and Piping Components
  • Material Handling and Warehousing
  • Utility Systems

In the “black book”, it was emphasized that one effective approach is to evaluate compliance on a per-equipment basis, ensuring each piece of equipment meets the required codes and standards. This involves:

  1. Identify Applicable Standards

First, determine the relevant RAGAGEP(s) for each type of equipment. Key organizations publishing RAGAGEP include, but are not limited to:

  • International and State Laws and Regulations e.g. California Accidental Release Prevention (CalARP), Program New Jersey Toxic Catastrophe Prevention Act (TCPA), European Union Seveso Directive, Canadian Environmental Protection Act (CEPA), UK Control of Major Accident Hazards (COMAH) Regulations
  • Voluntary Industry Standards e.g. International Organization for Standardization (ISO) Standards (e.g., ISO 31000 for risk management), American Chemistry Council Responsible Care® Management System, and American Petroleum Institute Recommended Practices (e.g. API RP 752 for managing process hazards in petroleum refineries, emphasizing safe design and operation)
  • Consensus Documents e.g. American Petroleum Institute (API) Standards (e.g., API 520/521 for pressure relief systems), American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, National Fire Protection Association (NFPA) Codes (e.g., NFPA 30 for flammable and combustible liquids), International Institute of Ammonia Refrigeration (IIAR), and American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE)
  • Professional Societies and Industry Groups e.g. Center for Chemical Process Safety (CCPS) publications and guidelines, American Institute of Chemical Engineers (AIChE), and Institution of Chemical Engineers (IChemE)
  • Corporate Standards e.g. Company-specific engineering design standards and practices and safety policies and procedures developed by individual companies
  1. Create Detailed Checklists

Develop checklists that include all necessary inspection, maintenance, and operational requirements based on the identified standards. Each checklist should cover design specifications, operational guidelines, and maintenance schedules. For example, checklists might reference ASME B31.5 for refrigeration piping or NFPA 70 for electrical safety.

  1. Conduct Thorough Reviews

Use the checklists during PHAs to methodically review each piece of equipment. Ensure that all design and operational practices align with the latest RAGAGEP. This step-by-step approach helps identify any gaps or areas needing improvement.

  1. Document Findings and Actions

Record the findings of each review and the actions that need to be taken to address any non-compliance. This documentation ensures a clear audit trail and helps maintain ongoing compliance with RAGAGEP.

In Conclusion

Saltegra Consulting LLC, a process safety and risk management consulting company, is well-positioned to assist facilities in effectively applying RAGAGEP within their PSM programs and PHAs. Saltegra can guide facilities through the implementation of RAGAGEP in the evolving regulatory landscape, ensuring adherence to the latest safety regulations. Saltegra’s comprehensive services include conducting thorough reviews of existing practices, developing detailed checklists, and providing tailored recommendations based on the latest industry standards. With this, facilities can enhance their compliance with RAGAGEP. Saltegra’s commitment to delivering reliable and tailored solutions ensures that facilities can navigate the complexities of PSM and achieve sustained compliance.