Washington – Thomas M. Galassi, director of OSHA’s Directorate of Enforcement Programs, on May 11 sent a memorandum to regional administrators regarding the Process Safety Management Standard’s recognized and generally accepted good engineering practices requirements, also known as RAGAGEP.
The document replaces the agency’s previous memorandum on the issue, which was sent June 5, 2015. The revised version does not include any significant changes, but it clarifies some of the wording in the document to try to eliminate potential misinterpretations.
The PSM standard states that RAGAGEP pertains to process equipment design and maintenance, inspection and test practices, and inspection and test frequencies.
“Enforcement activity, including the Petroleum Refinery Process Safety Management National Emphasis Program (Refinery NEP), and requests for assistance from the field, revealed the need for this guidance,” Galassi wrote. “It is intended to be a clarification of the policy described in the earlier memorandum and does not reflect any substantive change in OSHA enforcement policy.”
