OSHA issue Enforcement Policy Memo to Regional Administrators on "RAGAGEP in Process Safety Management Enforcement"
May 11, 2016 MEMORANDUM FOR: REGIONAL ADMINISTRATORS THROUGH: DOROTHY DOUGHERTY, Deputy Assistant Secretary FROM: THOMAS M. GALASSI, Director Directorate of Enforcement Programs SUBJECT: RAGAGEP in Process Safety Management Enforcement
NOTE: much of the emphasis has been added by me This enforcement policy addresses the Process Safety Management (PSM) Standard's recognized and generally accepted good engineering practices (RAGAGEP) requirements. Enforcement activity, including the Petroleum Refinery Process Safety Management National Emphasis Program (Refinery NEP), and requests for assistance from the field, revealed the need for this guidance. This memorandum rescinds and replaces the memorandum of the same title dated June 5, 2015. It is intended to be a clarification of the policy described in the earlier memorandum and does NOT reflect any substantive change in OSHA enforcement policy. Background on Recognized and Generally Accepted Good Engineering Practices The PSM Standard, 29 CFR 1910.119, directly references or implies the use of RAGAGEP in three provisions: |
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