Thus, if employers have identified these standards or documents as RAGAGEP and are following the requirements laid out in these documents, then they likely will be in compliance with the standard’s requirements.
OSHA also recognizes that non-consensus engineering documents or peer-reviewed technical articles addressing specific hazards may serve as RAGAGEP when published standards are not available or are not adequate to address specific hazards.
These enforcement considerations can serve as a roadmap for the areas that the inspector will analyze during a PSM-inspection.
Therefore, in considering how to spend valuable resources, it would be wise for an employer to focus on the enforcement considerations discussed in the memorandum.
The guidelines are developed jointly with the industry and the relevant professional bodies.
OSHA issues new guidance to Regional Administrators and State Plan Designees on the enforcement of the Process Safety Management (PSM) standard’s recognized and generally accepted good engineering practices (RAGAGEP) requirements.
The new guidance clarifies OSHA’s positions with respect to enforcing the PSM standards that reference or imply the use of RAGAGEP. § 1910.119 should carefully review their compliance with the following standards in light of this new guidance and OSHA’s renewed focus on the proper application of RAGAGEP to covered processes and equipment: Issuance of this memorandum signals that inspectors will be looking more closely at these requirements during PSM-related inspections and that they will specifically be looking for information on whether employers have identified and documented the appropriate RAGAGEP that applies to each piece of equipment and are following the inspection and testing requirements including frequency of those inspections and tests.
The memorandum provides the most detailed information on how OSHA will handle PSM inspections with respect to the RAGAGEP requirements and it includes 16 detailed enforcement considerations that inspectors will evaluate when reviewing an employer’s compliance. In this enforcement memorandum, OSHA recognizes that while the PSM standard does not define RAGAGEP and employers may select the RAGAGEP that will apply to their covered processes, there are several consensus standards that are widely adopted by federal, state and municipal jurisdictions and are generally accepted by OSHA as RAGAGEP.
One of the most confusing things about applying RAGAGEP requirements for both employers and inspectors is the application of “shall” and “should” found in the language of consensus standards and documents.
OSHA attempts to clarify the meaning of these terms and the responsibilities of the employer in applying each.
The memorandum also provides specific guidance on when citations may be issued. Those standards include the National Fire Protection Association (NFPA) 101 Life Safety and NFPA 70 National Electric.
In addition to these consensus standards, there are several published consensus documents that are widely used by certain PSM-covered industries and are generally accepted by OSHA as RAGAGEP, such as ASME B32.3 .
For a good year now the 15th supplementary guideline to the EC-GMP Guide (Annex 15) has been available in draft form (see GMP-News no. The commentary on this draft was completed by spring of this year.