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| We are experienced in the thirteen parts of Process Safety Management, as required by OSHA 29 CFR 1910.119, and can provide expert assistance with your program, particularly with conducting Process Safety Reviews aka Process Hazard Reviews. We are also experienced and ready to assist with the development of RAGAGEP programs to meet new requirements by OSHA officials. RAGAGEP is an acronym for “Recognized And Generally Accepted Good Engineering Practices”, and is specific language in Federal Statutes from OSHA and EPA, and is also mentioned in the American Chemistry Council (ACC) Responsible CareR Process Safety Code. “Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.” [EPA 40 CFR 68, part 68.56 (d)] “The employer shall document that equipment complies with recognized and generally accepted good engineering practices.” [OSHA 29 CFR 1910.119 (D) (3) (ii)] “Each member company shall have an ongoing process safety program that includes... Facility design, construction, and maintenance using sound engineering practices consistent with recognized codes and standards.” [American Chemistry Council (ACC) Responsible CareR Process Safety Code, Management Practices for Facilities] What should the Owner do to meet the requirements for conformance?
Please CONTACT US for assistance with: Recommend what RAGAGEP’s that the Owner should use. Assist in assembling RAGAGEP documentation. Develop RAGAGEP implementation plans. Perform engineering to provide baseline RAGAGEP documentation. Write contract bid packages to insure that the construction meets applicable RAGAGEP’s. Develop inspection and testing programs. Perform suitability for service evaluations. Develop uniform plant Piping Specification with service index. FREQUENTLY ASKED QUESTIONS: What is a RAGAGEP? A RAGAGEP is a consensus code, standard or guideline that documents the engineering practices for the design, fabrication, installation, maintenance, and/or inspection and testing of equipment. A RAGAGEP can be:
Moreover RAGAGEP’s define the standard of care expected of Owners by government and the public in operating a chemical manufacturing (and other) business. Why are RAGAGEP programs needed? By purchasing equipment manufactured to recognized and accepted standards, by installing that equipment in accordance with recognized and accepted standards, by maintaining and inspecting that equipment in accordance with recognized and accepted standards, and by maintaining records that these standards were followed, the Owner significantly reduces the potential risk associated with injuries or damage to private property that may be caused by an equipment failure or accident. The Owner retains ultimate responsibility for insuring that manufacturers, contractors, inspectors, and maintenance personnel use and abide by current applicable codes and standards. Can the Owner afford the cost of compliance? YES! Compliance is good business. Today, business is:
Distrusted by the public and viewed as “the enemy”, particularly the Chemical Process Industry. Seen by the public as having “deep pockets”. The last two items in the list above leave the Owner open for substantial risk if he does not meet today’s expected level of care. Compliance should be used to industry’s advantage. In today’s litigant society, and as seen by examining the factors above, lack of compliance can potentially put a company out of a market in which it participates, or even out of business. We would appreciate the opportunity to assist you in setting up an efficient and cost effective RAGAGEP program. |
| J. G. HUDSON & ASSOCIATES, PC P.O. BOX 4064 SALISBURY, NC 28145 704-637-1714 |
| PROCESS SAFETY MANAGEMENT / RAGAGEP |
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