Drawing on a review of regulatory and other documents and interviews with industry stakeholders, the author presents the origin and intention of recognized and generally accepted good engineering practices (RAGAGEP), points of disagreement about the definition, and recommendations for the California Division of Occupational Safety and Health to bring industry and government into better alignment about expectations for complying with RAGAGEP.
- How has RAGAGEP been interpreted and experienced by industry stakeholders?
- How might industry and government interpretations of RAGAGEP become better aligned?
Process safety management (PSM) is a suite of risk management elements designed to minimize the risk of accidents associated with industrial processes using highly hazardous materials. The California Division of Occupational Safety and Health (Cal/OSHA) PSM regulation requires that process equipment and equipment inspection and testing adhere to recognized and generally accepted good engineering practices (RAGAGEP). This term was introduced to allow the regulation to incorporate by reference all relevant consensus codes and standards, engineering society technical reports, and other technical specifications without specifically referencing each individual document (of which there are hundreds).
Although it is well-intentioned, the definition of RAGAGEP is not sufficiently clear. Lack of consensus about the definition has led to confusion and disagreement between industry and government regulators. Drawing on a review of regulatory and other documents and structured interviews with industry stakeholders, the author presents the origin and intention of RAGAGEP, the points of confusion and disagreement about the definition, and recommendations for Cal/OSHA to help clarify the definition and bring industry and government into better alignment about expectations for complying with RAGAGEP in the PSM regulation.
- The Occupational Safety and Health Administration's original intention in introducing the term RAGAGEP was to refer to the most current edition of whatever consensus standards and codes applied; however, the definition was expanded in response to protests from industry.
- From its inception, lack of clarity about the definition and interpretation of RAGAGEP has been a source of confusion and disagreement.
- Stakeholders noted that knowledge about RAGAGEP was not centralized within a facility but distributed across diverse subject-matter experts and resources.
- Approaches to documentation of process equipment compliance were mixed, and interview participants noted such challenges as unclear connections among manufacturers' specifications, installation documentation, or both.
- A key concern among refinery operators is that California's PSM regulation for petroleum refineries defines RAGAGEP to exclude standards, guidelines, or practices developed for internal use by the employer, despite the regulation allowing employers to use internal standards as long as they are more protective than RAGAGEP.
- Some participants were confident that their internally developed designs or procedures were more protective than RAGAGEP. However, there is no method that industry could be confident that government regulators would accept for demonstrating this level of protection.
- Refinery representatives said that the terms should or should not did not affect interpretations of RAGAGEP, but other participants said that this was an important controversy.
- Develop a definitive list of organizations that qualify as sources of RAGAGEP.
- Indicate what types of documents qualify as RAGAGEP.
- Eliminate the word should from RAGAGEP.
- Develop clear guidance for how to evaluate the protectiveness of internal standards.