(55g) Practical Notes on Ragagep Compliance

Process Safety Management (PSM) and Risk Management Plan (RMP) regulations have long required facilities to ensure that they comply with Recognized and Generally Accepted Good Engineering Practice (RAGAGEP). In recent years, authorities having jurisdiction have placed increased emphasis on RAGAGEP compliance. Specifically, emphasis has been placed on documentation and compliance with the industry codes and standards to which a facility is designed and maintained. This poses a unique challenge to older facilities, which have been designed to codes and standards long out of date and especially to owners and operators that do not have access to engineering documents used in the original design of their facility. For facilities using outdated codes, OSHA requires that the operating company document that “equipment is designed, maintained, inspected, tested, and operating in a safe manner.”

Over time, the gradual evolution of industry codes and standards may cause facilities to fall out of compliance with the RAGAGEP requirements of the regulations. This paper provides example cases based on authors’ experience with various owners and operators of older facilities. Practical methods are discussed for achieving and maintaining RAGAGEP compliance. It includes examples of comparing systems designed to outdated codes and standards against the latest codes, to ensure that they are able to maintain compliance with RAGAGEP.