What are the requirements when a component in my covered process was built to an OLD "out of circulation" RAGAGEP?
This is a very common question when auditing "older plants", say plants built prior to 1960 (not a specific date with any meaning). For example, during an audit it is discovered that a vessel was built to a RAGAGEP that no one had even heard of or maybe there is NO documentation as to what the vessel was built to. Is this a compliance issue and if it is what must the facility do to meet the PSM/RMP requirements? |
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