'Shall' 'Should' - RAGAGEP in Process Safety Management Enforcement Gas Processors Association 2016 Annual Convention

摘要

This article is part of an educational series of Process Safety Lifecycle Seminars, which was developed to help business leaders and managers gain a general understanding of existing industry standards and best practices for RAGAGEP - “Recognized and Generally Accepted Engineering Practices”. The GPA presentation will provide a practical overview of the compliance lifecycle requirements, including checklists and key considerations for each phase of the lifecycle. In June of 2015, OSHA redefined their interpretation of the Process Safety Management (PSM) standard 29CFR 1910.119. In a memorandum to their CSHO enforcement personnel, OSHA vastly expanded the requirements for RAGAGEP at all PSM facilities. The requirements range from broad to narrow, prescriptive to ambiguous. Some facility operators may understand what they need to do, others may be uncertain about how to comply. This editorial is designed to inform facility owners what they must, should and shall do to meet the new interpretation of the PSM standard. While many requirements can be delegated by an employer to a consultant or engineering firm, some cannot. What follows is a summary of the OSHA memorandum, guidance relative to the process industry standards and how it infers the adoption of the CCPS definition for RAGAGEP found in the Center for Chemical Process Safety’s (CCPS) “Guidelines for Mechanical Integrity Systems”. This summary also addresses the potential enforcement activity by OSHA Certified Safety and Health Official’s (CSHO’s), which began inspecting industrial facilities more than 2 decades ago with the Petroleum Refinery Process Safety Management National Emphasis Program (Refinery NEP) and how that experience could affect PSM enforcement in the gas processing industry.