RAGAGEP: Just what is it?

RAGAGEP stands for Recognized and Generally Accepted Good Engineering Practice.

OSHA: OSHA 29 CFR 1910.119 (D)(3)(ii): “The employer shall document that equipment complies with recognized and generally accepted good engineering practices.”

EPA: EPA 40 CFR 68.73 (d)(2): “Inspection and testing procedures shall follow recognized and generally accepted good engineering practices”

Simply put RAGAGEP is just the standards and practices that the majority of the industry follow. For ammonia refrigeration you generally refer to the ANSI/IIAR standards. OSHA dealt with the question of RAGAGEP (specifically about whether you need to update equipment to meet new standards) in a 2006 interpretation:

Question 9: Which ANSI/IIAR standard will OSHA deem to be applicable to a system built prior to 1999?

Response 9: If an employer was in compliance with PSM for a process built before 1999, then it will have PSI which shows the design codes and standards employed for the equipment in its covered process, 29 CFR §1910.119(d)(3)(i)(F). Additionally, all equipment in the covered process was designed, fabricated, installed, operated, inspected/tested/maintained, and changed per some RAGAGEP. To manage and ensure this, employers have documented per 1910.119(d)(3)(ii) that the equipment complies with RAGAGEP. This documentation established the “fitness-for-duty” for the equipment and became the baseline for all future operation, inspection/testing/maintenance, and change. Once this baseline has been established and the employer follows all PSM requirements including all applicable RAGAGEP, OSHA generally does not require the employer to upgrade its covered equipment to meet a change in a latter version of some RAGAGEP. The only exception to this would be if the equipment was being changed and an applicable RAGAGEP required that the equipment be updated to meet the latest version of the RAGAGEP. It is important that employers identify and document RAGAGEP for covered equipment, as that is the basis for managing the safety of the equipment over its lifetime.

Therefore, if the employer documented that it used ANSI/IIAR 2 — 1992 as one of the codes and standards it employed [per 1910.119(d)(3)(i)(F)] for some aspect of a covered process which was started-up in 1994, and if the employer documented that the covered process met the RAGAGEP requirements of 1910.119(d)(3)(ii), OSHA would not require the employer to comply with the requirements of ANSI/IIAR 2 — 1999. This assumes the employer has followed all PSM requirements and there are no equipment updates or changes required by ANSI/IIAR 2 — 1999 or some other latest version of an applicable RAGAGEP.

So the short version is: You define the design criteria (code, IIAR, etc.) and then you will be held to it.

About Brian Chapin

PSM / RMP Compliance Consultant
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