ArticlesRAGAGEPs and "the numbers"
The use of Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) has become a common occurrence since OSHA's Process Safety Management standard and EPA's Risk Management Plan rule came out in the 1990's Some professionals have come to hate RAGAGEPs and wish for the good ole days when OSHA promulgated prescriptive standards like 1910.23; and then there are others who work diligently to dissect the RAGAGEPS looking for every loophole they can possibly find in order to do as little as possible in their attempt to comply with these baseline standards... and here lies the problem! There are not many published RAGAGEPs that require some baseline expectations in their implementation; however, there are some in the process safety arena that will argue that if the RAGAGEP does not specifically require it (or prohibit it) then it is NOT required (or a violation of said code); but my position is with the RAGAGEPs come some basic expectations... |
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