OSHA memo on RAGAGEP in Process Safety Management Enforcement

Details
Parent Category: Safety Info Posts
Category: Chemical Process Safety (PSM/RMP)

This memorandum provides guidance on the enforcement of the Process Safety Management (PSM) Standard’s recognized and generally accepted good engineering practices (RAGAGEP) requirements, including how to interpret “shall”  and “should”  language in published codes, standards, published technical reports, recommended practices (RP) or similar documents, and on the use of internal employer documents as RAGAGEP.  Enforcement activity, including the Petroleum Refinery Process Safety Management National EmphasisProgram (Refinery NEP), and requests for assistance from the field, revealed the need for guidance on the PSM standard’s RAGAGEP provisions.

Comments   

#2 Bryan 2015-06-18 00:30
Brenda, each piece of equipment handling the HHC/EHS needs to be designed, built, installed, operated and maintained per your chosen RAGAGEP(s). I wrote an article last year about how we should document our pressure vessel(s) meet our chosen RAGAGEP. There is no single document that will do this for us. The name plate and the U1 form establish the vessel was built to a code, but we need inspection records BEFORE it was placed into service. Items like pressure/vac test results; welding tie-in NDE/NDT results, the relief system is in place and sized properly, the vessel is labeled properly, etc. One thing we typically find is a "used" vessel was NOT designed for the process and was sort of hodged podged into place to save $ vs buying a new vessel.
#1 Brenda Seggerman 2015-06-17 17:29
Given this memo, what is the best way to document RAGAGEP? Having the U1 form for a coded vessel? Making sure the name plate is visible on a API 650 tank or having the prints for it that state it's a 650 tank?

Thanks

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