We continue our series of posts on the topic of Safety in Design. The first nine posts were,
The next two posts will be to do with the topic of RAGAGEP.
The acronym RAGAGEP stands for ‘Recognized and Generally Accepted Good Engineering Practices’.
The first step in applying RAGAGEP is to make sure that codes and standards are being properly followed. However, there are situations where a relevant code or standard may not exist, is out of date, is ambiguous, or is open to interpretation.
This is where RAGAGEP comes into play. Engineers and designers, using good judgment that is based on reputable sources, determine if a particular design decision makes sense for the context in which it is being used. (RAGAGEP is used primarily in design work. However, it can also be used in other situations, such as audits and assessments.)
Many regulatory bodies recognize that they cannot provide rules for all situations. Therefore, regulators such as OSHA, the EPA and the American Chemistry Council (ACC) all accept the use of RAGAGEP. For example, the EPA says,
EPA expects owners and operators to regularly review new and updated RAGAGEP applicable to their industry to determine where safety gaps exists within their current process.
The following is from the OSHA standard, 29 CFR 1910.119,
(d)(3)(ii): Employers must document that all equipment in PSM-covered processes complies with RAGAGEP;
(j)(4)(ii): Inspections and tests are performed on process equipment subject to the standard's mechanical integrity requirements in accordance with RAGAGEP; and
(j)(4)(iii): Inspection and test frequency follows manufacturer's recommendations and good engineering practice, and more frequently if indicated by operating experience.
OSHA Guidance
In May 2016, OSHA issued the guidance document ‘RAGAGEP in Process Safety Management Enforcement’. It is lengthy. The following are the first four points from that section. (Occupational Safety and Health Administration, 2016).
There may be multiple RAGAGEP<s> that apply to a specific process. For example, American Petroleum Institute (API), RP 520 Sizing, Selection, and Installation of Pressure-Relieving Devices in Refineries Part II - Installation, and International Standards Organization, Standard No. 4126-9, Application and installation of safety devices, are both RAGAGEP for relief valve installation and contain similar but not identical requirements. Both documents are protective and either is acceptable to OSHA.
Employers do not need to consider or comply with a RAGAGEP provision that is not applicable to their specific worksite conditions, situations, or applications.
Some employers apply RAGAGEP outside of their intended area of application, such as using ammonia refrigeration pressure vessel inspection recommended practices in a chemical plant or refinery process. Use of inapplicable RAGAGEP can result in poor hazard control and can be grounds for citations.
There may be cases where the selected RAGAGEP does not control all of the hazards in an employer's covered process. As discussed above, the employer is expected to adopt other RAGAGEP (potentially including internal standards, guidance, or procedures) to address remaining process hazards. Whether internal standards constitute RAGAGEP should be reviewed on a case-by-case basis.
Development of RAGAGEP
The development of RAGAGEPs for a particular company or facility typically includes the following steps:
Identify the relevant federal, state, county and local regulations.
Identify local codes and standards (such as building and fire codes).
Identify the pertinent industry consensus standards from organizations such as the American Society of Mechanical Engineers (ASME), the American National Standards Institute's (ANSI), and the National Fire Protection Association (NFPA).
Identify pertinent documents that may not have industry consensus but are nevertheless considered to be authoritative. Examples are the Chlorine Institute’s pamphlets on chlorine and sodium hypochlorite (bleach) safety. The many publications from the Center for Chemical Process Safety (CCPS) are particularly important non-consensus documents with regard to process safety. Peer-review articles and papers also fall into this category.
Review all of the above with legal, safety and environmental staff.
Incorporate proprietary experience and standards.
Finalize with engineering judgment.
Update as new standards, regulations and practices are issued and adopted.
Circular Reasoning
Like so many other process safety elements, there is a danger of falling into the trap of self-referential reasoning. What constitutes ‘Recognized’ and ‘Generally Accepted’? There are bound to be differences of opinion between experts. It is all too easy to fall into circular logic of the following form.
Who defines ‘recognized and good engineering practice’?
Engineering experts.
What makes them engineering experts?
They establish ‘recognized and good engineering practice’.
