Both OSHA's and EPA's process safety standards have a requirement called "Design codes and standards employed", but why do the standards require this and what should it look like in our Process Safety Information management system?  In a review of our past audits, we almost always find gaps in the facility's list of Design codes and standards employed. 

Here are the regulatory requirements:

OSHA's PSM states:

1910.119(d)(3)(i)(F) Design codes and standards employed;


EPA's RMP states:

Program 2 

§68.48 Safety information.

(5) Codes and standards used to design, build, and operate the process.

Program 3

(vi) Design codes and standards employed;


It is actually EPA's RMP Program 2 requirement that begins to explain what the requirement is actually intended to document... Codes and standards used to design, build, and operate the process.  Although it does leave out one critical aspect to process safety - Mechanical Integrity of the process.  But as we can see, the intent is for the employer/owner/operator to document the codes/standards they used to

  1. DESIGN,
  4. OPERATE and

the covered process.  To better understand why OSHA/EPA want this documented we have to go back to the very basic understanding that both PSM and RMP are "performance oriented" standards and thus it is up to the employer/owner/operator as to which codes/standards are best suited for their particular covered process.  Granted some of these codes/standards may be used facility-wide and some may be process specific, but it is REQUIRED that we document which codes/standards were used.

I have always just had a list of the codes/standards that were used.  This list even included the revision/edition that was used.  

The listing of the codes/standards employed can actually come in handy.  For example, when an engineer wants to expand the process and he/she needs to know which Pressure Vessel code/standard to use, it is listed.  He/she would also be able to find the Relief Valve design code/standard for the vessel, the piping code/standard used, the bonding/grounding code to use, the ventilation code to use, etc.  This "list" ensures continuity for the process safety and ensures the most practical codes/standards are being used.  Should someone want to use a different code/standard or maybe not follow one of the established codes/standards for their modification/expansion, then that should undergo a Management of Change review.

So when OSHA or EPA arrive for an inspection and ask us for the Design codes and standards employed used in our covered process(s) we should be able to:

  1. Provide them a list of these codes/standards
  2. Provide them a copy of the actual codes/standards
  3. Provide them evidence that the codes/standards requirements were met.

Being able to meet all three (3) of the above-listed items will go a long ways in demonstrating... that equipment complies with recognized and generally accepted good engineering practices (1910.119(d)(3)(ii).  As noted in OSHA's FY2014-2016 Chem Nep Update, the #1 cited Element was Process Safety Information (PSI) and the #1 cited PSI issue was... "PSI RAGAGEP compliance".  I do not have the data to state this with 100% confidence, but I can say for sure, based on the hundreds of PSM/RMP citations I have collected over the years that almost all of these citations will fall into 1 of 2 categories:

  1. The company failed to document which RAGAGEPs were used
  2. The company failed to demonstrate they followed their chosen RAGAGEPs

There are many OSHA and EPA citations where OSHA/EPA has cited an employer/owner/operator for not adopting a RAGAGEP for a major component of their process, most notably their piping; the two (2) most common in PSM/RMP processes being ASME B31.3 or 31.5.  And there are many OSHA and EPA citations where OSHA/EPA has cited an employer/owner/operator for not following their chosen piping RAGAGEP when they installed the piping, failed to label the piping, nor maintain the piping. NOTE: SAFTENG Members should read Making the case my PSM/RMP covered process complies with RAGAGEPs (Piping)


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