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‘Search [Ato ZIndex [En Espafol [Contact Us FAQS ‘About OSHA OSHA Newsletter RSS Feeds Menu Occupational Safety & Health Administration We Can Help Stondard Intoretation Tale of Contents ‘* Standard Number: 1910119 (OSHA requirements are set by statute, standards and regulations. Our interpretation eters explain these requirements and how they apply to particular Ccrcumstances, but they cannot create adtional employer obligations. Ths eter constitutes OSHA's interpretation of the requirements cscussed, Note that our enforcement guidance may be aflected by changes to OSHA rules, Also, fram me to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at hto://marw.osha.gov sune 5, 2015 MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES -ruroucH: DOROTHY DOUGHERTY Deputy Assistant Secretary “THOMAS GALASSI Director Directorate of Enforcement Programs FROM: SUBJECT: RAGAGEP in Process Safety Management Enforcement “This memorandum provides guidance on the enforcement of the Process Safty Management (PSM) Standard’s recognized and generally accepted good engineering practices (RAGAGEP) requirements, including how to interpret shall” and “should” language in published codes, standards, pubished techrical reports, recommended practices (RP) or similar documents, and an the use of internal employer deciments as RAGAGEP. Enforcement activity, including the Petroleum Refinery Process Safty Management Nabonal Emphasis Program (Refnery NEP), and requests for assistance from the fed, revealed the need for guidance on the PSM standara's RAGAGEP provisos, Background on Recognized and Generally Accepted Good Engineering Practices “The PSM Standard, 29 CFR 1910.119, direct references or implies the use of RAGAGE? in three provisions: + (C3): Employers must document that all equipment in PSH-covered processes complies with RAGAGEP; + GCN: Inspections and tests are performed on process equipment subject to the stanard's mechanical integrity requirements in accorcance with RAGAGEP; and + G)C@NEl: Inspection and test fs rency follows manufactxe’s recommendations and good engineering practice, and more frequently if indicates by operating experience. In adeition, (4)(3){ il) addresses situations where the design codes, standards, or practices used in the design and construction of existing equipment are no longer in general use. “The PSM standard does not define RAGAGEP. However, the Refinery National Emphasis Program (CPL 03-00-010) references the defriton found in the Center for Chemical Process Safety (CCPS) Guidelines for Mechanical Integrity Systems: “Recognized And Generally Accepted Good Engineering Practices" (RAGAGEP) - are the bass for engineering, operation, or maintenance activites and ae themselves basec on establshed codes, standards, published technical reports or recommended practoes (RP) or siralar documents. RAGAGEP detail generally approved ways to perform specific engineering, inspection or mechanical integrity actives, such as fabricating vessel, inspecting a storage tank, or servicing a rele va, ‘As used in the FSM standard, RAGAGEP apply o process equipment design, instalation, operation, and maintenance; inspection and test practices; and Inspection and test frequencies, RAGAGEP must be both "recognized and generally accepted” and "good engineering” practices, “The PSM standard allows employers to select the RAGAGEP they apply in thelr covered processes Primary Sources of RAGAGEP 1. Published and widely adopted codes Certain consensus standards have been widely adopted by federal, state, or municipal juristicions. For example, many state and muncipal bulling and other codes incorporate or adopt codes such asthe National Fite Protection Associaton (NFPA) 101 Life Safely and NFPA 70 National Electric codes, Such published and widely accepted codes are generally acepted by OSHA as RAGAGE?, as are Federal, state, ad municipal laws and reguatons serving the same purposes, 2. Published consensus documents Certain organizations lke the American Society of Mecharical Engineers (ASME follow the American National Standards tnstiue's (ANS!) Essential Requirements: Due process requirements for American National Standards (Essential Requrements) when publishing consensus standards and recommended practices. Under the ANSI and similar requirements, these organizations must demonstrate that they have diverse and broadly representative committee memberships. Examples of published consensus documents include the ASME 831.3 Process Ping Code and the International Institute of Ammonia Retigeration’s(IIAR) ANSI/IIAR 2-2008 - Equipment, Design, and Installation of Closed-Cirait Ammonia Mechanical Refrigerating Systems. Published consensus documents are very wiely used as RAGAGEP by those knowledgeable inthe industry, and are accepted as RAGAGEP by OSHA. 3, Published non-consensus documents ‘Some inusties pubish non-consersus engineering documents using processes net conforming to ANSI's Essential Requirements. For example, the Chlorine Intte's (C1) “pamphlets” focus on chore and sodium hypochlorite (bleact) safety, Where applicable, the practices described in these documents are widely accepted as good practices and used in Industries handing these materials. Similarly, CCS publshes an extensive set of guideline books, some, but not al, of which deal with process equipment spectc topic, e.g, the Design Institute for Emergency Rel Systems’ technology for reactive and mult-phase relief systems design', Peer-reviewed technical articles addressing specific hazards may also fl into this category and may be considered when publshed standards or recommended practices are nat avallable or are not adequate to address specfic hazards. OSHA may accept such materials 35 RAGAGEP where applicable and appropriate Note that 29 CFR 1910.119()(4)) also recognizes applicable manufacturer's recommendations as potertial sources of RAGAGEP. “Appropriate Internal Standards” The preamble tothe PSM standard recognizes that employers may develop Internal standards for use within thelr facies. The preamble stats, In relevant part The phrase suggested by rulemaking partipants: “recognized and generally accepted good engineering practices” is consistent with OSHA's intent, The Agency also believes that his phrase would include appropriate internal stancards ofa facty...? [emphasis added} The preamble, however, doesnot imply that employers may disregard applicable published RAGAGEP.* Internally developed standards must stil represe “recognized and generally accepted good engineering practices.” Facility internal standards can serve @ numberof legate purposes including 1. Translating the requirements of published RAGAGEP into detailed corporate or faity implementation programs and/or procedures. 2, Setting design, instalation, maintenance, inspection, and testing recuirements for unique processes, ecuipment, anc hazards fo which no published RAGAGEP exists, 3. Supplementing (or augmenting) published RAGAGEP that onl parally or inadequately address the employes processes, occupancies, condions, and hazards. In this situation OSHA (and often the pubisher) expect emplayers/users to supplement the published RAGAGEP with their own applicable practices, protecals, and procedures to control hazards.* 4. Controling hazards more efecively tan the available codes, standards, or practices. 5 Addressing hazards when the codes and standards use for exsting equipment are outdated and no longer describe good engineering practce, Employers’ internal standards must ether meet or exceed the protective requirements of published RAGAGEP where such RAGAGEP exst, OSHA has rejected employer standards that devated from publsec RAGAGEP where the devitons wer les protecve than the published requirements, “Shall” and “Should” in RAGAGEP "Sha" "mus," or similar language used in published RAGAGEP reflects the developer's view thatthe practice isa mandatory minimum requirement to control a hazard, Simla, "shall na," prohiblted,”orsinlar language references or describes unacceptable approaches or practices. If an employer deviates from “shall” or “shall not” requirements in the employer's adopted RAGAGEP (or applicable RAGAGE? i the employer has not specited RAGAGEP), OSHA wil presume 2 Violation Use ofthe tem "shoul or similar language in the RAGAGE? reflects an acceptable and preferred approach, in the view of the publishing group, to controling a recognized hazard. Tf a selected RAGAGEP provision fs applicable tothe covered processor particular situation, OSHA presumes that employer compliance with the recommended approach is acceptable, 1 an employer chooses to use an alternate approach tothe one the published "should" RAGAGEP says applies, the CSHO should evaluate whether the employer has determined and documented tat the alternate approach sat least as protective, or thatthe published RAGAGE® i not applicable tothe employe’s ‘operation, In the absence of such documentation, the CSHO should examine documents, such as relevant process hazards analyses (PHAs) and management of change procedures (MOC), to determine ifthe employes approach is as protective as the publshed RAGAGEP and isa goad engineering practice, Ths may require consutation with Regional resources or the OSHA National Office (see below), "Should not” or similar languege describes disfavored or less than fly protective practices, Following such disfavored practices is presumed to be violative For tecnical help, corsut wth your Regional PSM Coordinator, technical support engineer, or contact the PSM group at OSHA's Directorate of Enforceme Programs - Ofce of Chemical Process Safety and Enforcement Intatives at 202-693-2341. “Normative” and “Informat Requirements. Published caces ane consensus documents frequent contain appendices or annexes that provide supplemental information and/or requirements, The content ofthese appentices or annexes may be normative" or informative.” "Normative" sections generally explain how to comply with the published code and/or consensus document requirements and may contain both “shall” and “should language. As discussed above, "shall" denotes the developers ew thatthe rormative statements mandatory, while “shoul” indicates an acceptable or preferred approach, “Informative” sections generally provide backyround and reference information with respect to the publ shed cade andor consensus document requirements but may also identify and/or address hazards or aceptable ‘means of abatement. Acain, for technical help, CSHOs should consut their Regional PSM coordinator, technical support engineer, or the fice of Chemical Process Safety and Enforcement Intiatwes. Other Uses of RAGAGEP Materials in PSM. Only the three sections oF 1910,119 referenced above require compliance with RAGAGEP. However, RAGAGEP can also provide useful background and conte, and can help CSHOs identity and document hazards and feasible means of abatement when reviewing other aspects ofthe employers PSM program and covered equipment Enforcement considerations In accordance with 1910.119, employers select the RAGAGEP with which their equipment ang procedures must comply. In evaluating RAGAGEP compliance, CCSHOs should be aware of a numberof potential issues 1, There may be multiple RAGAGEP that apply toa specific process, For example, American Petroleum Insitute (API), RP 520 Sizing, Selection, and Istalaton of Pressure-Relieving Devices in Refineries Part I - Installation, and International Standards Organizaton, Standard No, 4126-9, Applicaton ‘and installation of safety cevices, are both RAGAGEP for rellet vale instalation ane contain smile but not identical requirements Both documents are protective and ether is acceptable to OSHA, 2. Employers do not need to consider or comply with a RAGAGEP provision tat isnot applicable to their specific Wersite conitons, situations, oF application, 3 Some employers apply RAGAGEP outsde of their intended area of application, such as using ammonia refrigeration pressure vessel inspection recommended practices ina chemical plant or refinery process. Use of inapplicable RAGAGEP can result in poor hazard control and can be grounds for tations. 4, There may be cases where fully applicable RAGAGEP do not exist to control hazards in an employer's covered process, As discussed in "Appropriate Internal Standards", above, the employers interna standards (guidance and procedures) are expected to address the process hazards. Whether the Internal standards are adequately protective shouldbe reviewed on a case-by-case bass, 5. An employer's internal standards may be more stringent than the relevant published RAGAGEP. More-stringent standards may be needed to adequately contro hazards due tothe unique characteristics ofthe employer's process, This should be documented, Employers that meet published RAGAGEP requirements but thet fi to comply with their own more stringent internal requirements, may be citable under other PSM provisions = If there Is. fallure to folow more stringent internal Inspection & Test (I) procedures, consider cations under 1910.136()\2) for fallre to Implement thelr writen 187 procedures + Process equipment may be ouside acceptable limits defined in the employers PSI. Ifo, consider etatons under 1910.1199)). *= Adional or mare stringent equipment safeguards may be specied by employers based on findings end recommendations from PHAS end supporeng ocuments, such as Layers of Protecton Analyses, siting studies, human factors studes, Quantitative Rsk Assessments, and similar risk management actives, as well as Incident Investigations, or Management of Change procedures. Failure to implement or complete documented actons-to-be-aken ‘may be ced under the relevant section ofthe Standaré (e.g, 1910.119(e), (1), or (m)) 6, Selectively applying indvcual provisions from multiple RAGAGEP adcressing similar hazards might be inappropriate, Standard writing o-garizators develop thelr requirements as packages and mixing-and-matchng provisions from multiple sources coud result in inadequately controled hazards. This shuation should be evaluated on a case-by-case basis, Consult the regional PSM Coordinatr, regional enginee-ing Support, or the Office of Chemical Process Safty and Enforcement Initiatives if you are uncertain how to proceed 7, The PSM standard requires employers to document that their inspection ard testing of equipment, required under 1910.119()\4)i) ard (i), iin accordance with their selected RAGAGED, (e.9., 35 referenced in the written procedures required by 1910.119()(2)). allure to do so is citable. 8 In accordance with 1910,119(¢)(3)(W), employers must document that ther covered process equipment and equipment whose operation could affect that process equipment comply with RAGAGEP (equipment built to elder standards may come under 1919.119(d)(3)(), See paragraph 10 below). Equipment that does not comply wth RAGAGEP cannat be documented as complant. Therefere, bat te fllure to document compliance and the deviations fram compliance wth RAGAGEP can be cited under (4)3Xi) When writing 1910.119(6)(3)() RAGAGEP-related cation, always cite the employer for failing to document compliance with recognized and generally accepted god engineering practices, describe the hazard, e.g, exposure of employees to fre, explosion, or toxic hazards, and reference the RAGAGEP selected by the employer. Ifthe employer has not specfied an applicable RAGAGEP, use “such as" language to reference an applicable published RAGAGEP. 9. Equipment covered under PSM's Mechanical Itoi provstons (Isted in 1910.219()) that is ouside acceptable limits, as defined bythe process safety information (inluding RAGAGEP), is deficient under 1910.119()(5)- Employers are required by ths provson to correct deficiencies before further use arin a safe and timely manner when necessary means are taken to assure sae operation inthe interim. Tf an employe fails to correct the deficiency before further use, oF flisto implement adecuate interim measures and to schedule @ permanent correction timely, the fare may be cteé under 1910.119((5), If an employer has implemented interim measures and scheduled correction, additonal Investigation may be required to determine whether the interim ‘measures are adequate and the scheculed correction is timely. 1910.119(4)(3)i) and (5) cations are offen grouped. Consult your Regional OSHA support staff and/or SOL if you are uncertain if grouped cations are appropriate "Note, inthe case where an employer is operating deficient equipment based on the use of interim safeguards pending fina correction ofthe deficiency, 29 CFR 1910.119() requires thatthe employer develop anc implement @ menagement-of-charge procedure for the continued safe operation ofthe equipment, 10, Older covered equipment may not have been designed and constructed under an applicable RAGAGEP because none exsted atthe ime of design and construction, alteratvely the equipment may have been designed and constructed under provisions of codes, standards, or practices that are no longer in general use. In such cases, 29 CFR 1910.119(4)(3Xil) requires employers to determine and document thatthe equipment is designed, maintained, Inspected, tested, and operating ina safe manner, Fallur to do so may be cited under 1910,119(¢}3Xi) When writing 1910.119(6)(3)i) tations, alvays cite the employer for falling to determine and document thatthe relevant equipment design, ‘maintenance, Inspecion and testing, andor operation ensure the safety ofthe equipment Ifthe employer has adopted an appropriate internal standard applicable to such older equipment, 29 CFR 1910.119(4)(3)@) requires the employer to document thatthe equipment complies with the internal standard, Failure todo so may resultin a citation uncer 29 CFR 1910,119(¢) 3. 11, When 2 29 CFR 1910,119(6)3)) or (i) cation is under consideration, itis Important to establish ane to document the age ad installation date ofthe relevant process and equipment, andthe dates and extent of process and equipment modifications, as well as the exact RAGAGEP selected by the employer, Inducing the ection and publication date. 12, Organizations that publish RAGAGEP may update them based on newly identified or recognized hazards; improved understanding of existing hazards; industry operating experience; andor inciderts indicating that more stringent hazard controls needed. Ifthe updated RAGAGEP explictly provides that new causes or requirements are retroactive, OSHA expects employers that have selected that RAGAGEP to conform ta these provisions, Where RAGAGEP are Undated to be mare protective but are nat explitly retroactive, PSM does nat mandate that employers upgrade ther equipment, feces, or practices to ‘meet current versions of thr selected RAGAGEP. However, OSHA does expect employers to address Issues ralse¢ by or identified inthe updated RAGAGEP in accordance with 1910.119(€)(3)(i by determining and documenting that their equipment is designed, maintained, inspected, tested, and ‘operating in a safe manner, This can be accomplished through a variety of approaches, suchas but not limited to the PHA revalidation and management of change (MOC) processes, or trough corporate monitoring and review of published standards. Citations for 29 CFR 1810.119(6)(3)W), either stand-alone or grouped with, for example, (€)(3) er (N(1), may be appropriate ifthe employer falls to address the issues (se item 8 above). 13. Notify the Office of Chemical Process Safely and Enforcement Inatves if you encounter RAGAGEP that appear to have changed tobe less protective or that are being interpreted by employers in a manner that i less protective. Inthe past, OSHA determined that specic provsons in publishec guidance documents were not RAGAGEP (Le, OSHA belleved that some writen practices provided inadequate protection ane were not good engineering practices; therefore, the speatc practices in question could not be RAGAGEP). Such determinatons should only be made In consultation with the Office of Chemical Process Safty and Enforcement Iniatives. 14. When writing 1910.1196)\(4}i)cRations, always te the employer for fang to follow RAGAGE? ints inspection and testing procedures, and reference the relevant RAGAGEP adopted / recogrized by the employer, If the employer has not specified an applicable RAGAGEP, use “such a" language to reference ‘an applicable published RAGAGEP. When the employer's IT procedures comply with RAGAGE®, but are not implemented or followed, consider 1910.119()) (2) ctatons. 15. When writing 1910.1196)(4)i) cation, always cte the employer for not inspecting andor testing process ecuipment at frequencies consistent with applicable manufacturers’ recommendations and good engineerng practices, or more frequently i incicate by prior operating experience, ie, based on the condtion ofthe equipment when previously inspected or tested. 16, When writing RAGAGEP-elated ctatons when the employer has not specified a RAGAGEP, CSHOs shouldbe care to reference in the cations alleged Violation description only RAGAGE? that are actually applicable t the equipment and process being inspected. CSHOs have sometimes referenced inapplicable API relief valve RAGAGEP in citations involving ammonia refrigeration processes, 1 Many CCPS publications deal with management system isues and do not adress topics subject to RAGAG: 2 PSM preamble accessed at htp:/]wwew osha. govpls/oshawebjowadis.show_document?p_table=PREAMBLESEp 3 29 CFR 1910.139 Purpose; 57 Fed, Reg. 6390, 4For example: ANSI/IIAR 2-2008 Equpment, Design, and Intallaton of Closed-Crcut Ammonia Mechanical Refigrating Systems states, “This docume Intended to serve asa standard for equipment, cesgn and instalation of closed craut ammonia rerigeratng systems, Additonal requirements may be necessary because of particular circumstances, project specifications or other jurisdictional considerations. Note that tis standard does not constitute @ comprehensive detailed technical design manual and should not be used as such..." 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