Preparing for the OSHA Chemical NEP through RAGAGEP Compliance

The OSHA Refinery National Emphasis Program (NEP) and OSHA Voluntary Protection Program (VPP) PSM Supplement ask specific questions relative to many recognized and generally accepted good engineering practices (RAGAGEP). Mechanical Integrity (MI) and Process Safety Information (PSI) are the most frequently cited PSM elements, accounting for over 50% of the citations. Many of the same RAGAGEP can be expected in the planned OSHA Chemicals NEP as well, so chemical industry personnel should be aware of what RAGAGEP OSHA is recognizing and inspecting against and their key requirements, in order to comply with the OSHA PSM regulation and improve process safety at their sites. This presentation will review the RAGAGEP referenced by OSHA in its Refinery NEP and VPP documents and citations, highlight some of the key RAGAGEP which we often find not fully implemented/followed at petrochemical sites, and discuss approaches for complying with the requirements of these RAGAGEP.