RAGAGEP: A Subtle But Profound Change
Not ‘What Is’ but ‘What Might Be’
We continue our series of posts on the topic of Safety in Design. The first ten posts were,
We conclude the series with this post to do with proposed changes to OSHA’s Process Hazards Analysis regulation ― specifically the term ‘safer technology and alternatives analysis’.
In the year 2022 OSHA (the United States Occupational Safety & Health Administration) published proposed updates to its Process Safety Management standard, 29 CFR 1910.119. (Our book on the topic is The OSHA Process Safety Standard: The 30-Year Update.)
The update includes changes to do with the role of RAGAGEP in process safety programs. (We discuss the meaning of the term RAGAGEP ― Recognized and Generally Accepted Good Engineering Practice ― here.)
Language to do with RAGAGEP in the proposed update includes the following,
Amending paragraph (d) to require evaluation of updates to applicable recognized and generally accepted as good engineering practices (RAGAGEP).
<Paragraph (d) is to do with Process Safety Information>
Amending paragraph (b) to include a definition of RAGAGEP;
Expanding paragraph (e) by requiring safer technology and alternatives analysis
Paragraph (e) is to do with Process Hazards Analysis (PHA).
Process Hazards Analysis
The proposed change to paragraph (e) is subtle, but profound. OSHA is now calling on companies to evaluate risk not just in terms of ‘what is’, but ‘what might be’.
The goal of a PHA team is to identify hazards that could create unacceptable levels of risk. If the team does identify a hazard that poses unacceptable risk it generates a recommendation for follow up action. It is not the team’s job to identify what those actions may be, not least because the team members may lack the necessary expertise. It is not the team’s job to come up with solutions.
A PHA team is not a one-minute engineering department.
A PHA analyzes the technology that is being used, and then evaluates the associated risk. Now teams are being asked to look for alternative technologies.
(This change may apply during the analysis of a new process that is still in the design stage. In the early stages of a project it is possible that the team will be asked to compare the risks of two different technologies.)
The participants in a PHA are not likely to have the all the skills needed to develop, design and engineer ‘safer technology and alternatives’. But that seems to be what OSHA is looking for.
