{"id":770,"date":"2015-06-11T18:18:16","date_gmt":"2015-06-11T23:18:16","guid":{"rendered":"https:\/\/taocompliance.com\/?p=770"},"modified":"2015-06-11T18:18:16","modified_gmt":"2015-06-11T23:18:16","slug":"osha-memo-on-ragagep","status":"publish","type":"post","link":"https:\/\/taocompliance.com\/?p=770","title":{"rendered":"OSHA Memo on RAGAGEP"},"content":{"rendered":"<p><a href=\"https:\/\/www.osha.gov\/pls\/oshaweb\/owadisp.show_document?p_table=INTERPRETATIONS&amp;p_id=29414\" target=\"_blank\">Link to OSHA publication<\/a>\u00a0&#8211; Highlights (underline) are mine. Note that they reference the CCPS\u00a0<strong>again. <\/strong>The really good stuff is at the bottom in the notes to the inspectors.<\/p>\n<p>&nbsp;<\/p>\n<table class=\"table-condensed\" summary=\"Data Table\">\n<tbody>\n<tr>\n<td valign=\"top\"><strong>MEMORANDUM FOR:<\/strong><\/td>\n<td>REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES<\/td>\n<\/tr>\n<tr>\n<td><strong>THROUGH:<\/strong><\/td>\n<td>DOROTHY DOUGHERTY<br \/>\nDeputy Assistant Secretary<\/td>\n<\/tr>\n<tr>\n<td><strong>FROM:<\/strong><\/td>\n<td>THOMAS GALASSI Director<br \/>\nDirectorate of Enforcement Programs<\/td>\n<\/tr>\n<tr>\n<td><strong>SUBJECT:<\/strong><\/td>\n<td>RAGAGEP in Process Safety Management Enforcement<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<p style=\"text-align: justify;\">This memorandum provides guidance on the enforcement of the Process Safety Management (PSM) Standard\u2019s recognized and generally accepted good engineering practices (RAGAGEP) requirements, including how to interpret \u201cshall\u201d\u00a0 and \u201cshould\u201d\u00a0 language in published codes, standards, published technical reports, recommended practices (RP) or similar documents, and on the use of internal employer documents as RAGAGEP. \u00a0Enforcement activity, including the <em>Petroleum Refinery Process Safety Management National Emphasis<\/em> <em>Program<\/em> (Refinery NEP), and requests for assistance from the field, revealed the need for guidance on the PSM standard\u2019s RAGAGEP provisions.<\/p>\n<p style=\"text-align: justify;\"><strong>Background on Recognized and Generally Accepted Good Engineering Practices<\/strong><\/p>\n<p style=\"text-align: justify;\">The PSM Standard, 29 CFR 1910.119, directly references or implies the use of RAGAGEP in three provisions:<\/p>\n<ul style=\"text-align: justify;\">\n<li><span style=\"text-decoration: underline;\"><strong>(d)(3)(ii):\u00a0 <\/strong>Employers must document that all <strong>equipment <\/strong>in PSM-covered processes complies with RAGAGEP;<\/span><\/li>\n<li><span style=\"text-decoration: underline;\"><strong>(j)(4)(ii):\u00a0 Inspections and tests <\/strong>are performed on process equipment subject to the standard\u2019s mechanical integrity requirements in accordance with RAGAGEP; and<\/span><\/li>\n<li><span style=\"text-decoration: underline;\"><strong>(j)(4)(iii): <\/strong>Inspection and test <strong>frequency<\/strong> follows manufacturer\u2019s recommendations and good engineering practice, and more frequently if indicated by operating experience.<\/span><\/li>\n<\/ul>\n<p style=\"text-align: justify;\"><span style=\"text-decoration: underline;\">In addition, <strong>(d)(3)(iii)<\/strong> addresses situations where the design codes, standards, or practices used in the design and construction of existing equipment are no longer in general use.<\/span><\/p>\n<p style=\"text-align: justify;\">The PSM standard does not define RAGAGEP. However, the Refinery National Emphasis Program (CPL 03-00-010) references the definition found in the <span style=\"text-decoration: underline;\">Center for Chemical Process Safety\u2019s (CCPS)<em>Guidelines for Mechanical Integrity Systems<\/em>:<\/span><\/p>\n<p style=\"text-align: justify;\">\u201cRecognized And Generally Accepted Good Engineering Practices\u201d (RAGAGEP) &#8211; are the basis for engineering, operation, or maintenance activities and are themselves based on established codes, standards, published technical reports or recommended practices (RP) or similar documents. RAGAGEP detail generally approved ways to perform specific engineering, inspection or mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or servicing a relief valve.<\/p>\n<p style=\"text-align: justify;\">As used in the PSM standard, RAGAGEP apply to process equipment design, installation, operation, and maintenance; inspection and test practices; and inspection and test frequencies. \u00a0RAGAGEP must be both \u201crecognized and generally accepted\u201d <strong><em>and<\/em><\/strong> \u201cgood engineering\u201d practices.<\/p>\n<p style=\"text-align: justify;\">The PSM standard allows employers to select the RAGAGEP they apply in their covered processes .<\/p>\n<p style=\"text-align: justify;\"><strong>Primary Sources of RAGAGEP<\/strong><\/p>\n<ol style=\"text-align: justify;\">\n<li><strong>Published and widely adopted codes<\/strong>\n<p>Certain consensus standards have been widely adopted by federal, state, or municipal jurisdictions. \u00a0For example, many state and municipal building and other codes incorporate or adopt codes such as the National Fire Protection Association (NFPA) 101 <em>Life Safety<\/em> and NFPA 70 <em>National Electric<\/em> codes. \u00a0Such published and widely accepted codes are generally accepted by OSHA as RAGAGEP, as are Federal, state, and municipal laws and regulations serving the same purposes.<\/li>\n<li><strong>Published consensus documents<\/strong>\n<p>Certain organizations like the American Society of Mechanical Engineers (ASME) follow the American National Standards Institute\u2019s (ANSI) <em>Essential Requirements: Due process requirements for American National Standards<\/em> (Essential Requirements) when publishing consensus standards and recommended practices. \u00a0Under the ANSI and similar requirements, these organizations must demonstrate that they have diverse and broadly representative committee memberships. \u00a0Examples of published consensus documents include the ASME B31.3 <em>Process Piping Code<\/em> and the International Institute of Ammonia Refrigeration\u2019s (IIAR) ANSI\/IIAR 2-2008 &#8211; <em>Equipment, Design, and Installation of Closed-Circuit Ammonia Mechanical Refrigerating Systems<\/em>. \u00a0Published consensus documents are very widely used as RAGAGEP by those knowledgeable in the industry, and are accepted as RAGAGEP by OSHA.<\/li>\n<li><strong>Published non-consensus documents<\/strong>\n<p>Some industries publish non-consensus engineering documents using processes not conforming to ANSI\u2019s Essential Requirements. \u00a0For example, the Chlorine Institute\u2019s (CI) \u201cpamphlets\u201d focus on chlorine and sodium hypochlorite (bleach) safety. \u00a0Where applicable, the practices described in these documents are widely accepted as good practices and used in industries handling these materials. \u00a0Similarly, CCPS publishes an extensive set of guideline books, some, but not all, of which deal with process equipment specific topics, e.g., the Design Institute for Emergency Relief Systems\u2019 technology for reactive and multi-phase relief systems design<a id=\"anch_54\" title=\"Footnote\" href=\"https:\/\/www.osha.gov\/pls\/oshaweb\/owadisp.show_document?p_table=INTERPRETATIONS&amp;p_id=29414#ftn1\"><sup>1<\/sup><\/a>. \u00a0Peer-reviewed technical articles addressing specific hazards may also fall into this category and may be considered when published standards or recommended practices are not available or are not adequate to address specific hazards. OSHA may accept such materials as RAGAGEP where applicable and appropriate.<\/p>\n<p>Note that 29 CFR 1910.119(j)(4)(iii) also recognizes applicable manufacturer\u2019s recommendations as potential sources of RAGAGEP.<\/li>\n<\/ol>\n<p style=\"text-align: justify;\"><strong>\u201cAppropriate Internal Standards\u201d<\/strong><\/p>\n<p style=\"text-align: justify;\">The preamble to the PSM standard recognizes that employers may develop internal standards for use within their facilities. The preamble states, in relevant part:<\/p>\n<p class=\"offset1\" style=\"text-align: justify;\">The phrase suggested by rulemaking participants: \u201crecognized and generally accepted good engineering practices\u201d is consistent with OSHA\u2019s intent. The Agency also believes that this phrase would include <strong>appropriate<\/strong> internal standards of a facility . . .<a id=\"anch_55\" title=\"Footnote\" href=\"https:\/\/www.osha.gov\/pls\/oshaweb\/owadisp.show_document?p_table=INTERPRETATIONS&amp;p_id=29414#ftn2\"><sup>2<\/sup><\/a> [emphasis added].<\/p>\n<p style=\"text-align: justify;\">The preamble, however, does not imply that employers may disregard applicable published RAGAGEP.<a id=\"anch_56\" title=\"Footnote\" href=\"https:\/\/www.osha.gov\/pls\/oshaweb\/owadisp.show_document?p_table=INTERPRETATIONS&amp;p_id=29414#ftn3\"><sup>3<\/sup><\/a> \u00a0Internally developed standards must still represent \u201c<em>recognized and generally accepted<\/em> good engineering practices.\u201d<\/p>\n<p style=\"text-align: justify;\">Facility internal standards can serve a number of legitimate purposes, including:<\/p>\n<ol style=\"text-align: justify;\">\n<li>Translating the requirements of published RAGAGEP into detailed corporate or facility implementation programs and\/or procedures.<\/li>\n<li>Setting design, installation, maintenance, inspection, and testing requirements for unique processes, equipment, and hazards for which no published RAGAGEP exists.<\/li>\n<li>Supplementing (or augmenting) published RAGAGEP that only partially or inadequately address the employer\u2019s processes, occupancies, conditions, and hazards. In this situation OSHA (and often the publisher) expect employers\/users to supplement the published RAGAGEP with their own applicable practices, protocols, and procedures to control hazards.<a id=\"anch_57\" title=\"Footnote\" href=\"https:\/\/www.osha.gov\/pls\/oshaweb\/owadisp.show_document?p_table=INTERPRETATIONS&amp;p_id=29414#ftn4\"><sup>4<\/sup><\/a><\/li>\n<li>Controlling hazards more effectively than the available codes, standards, or practices.<\/li>\n<li>Addressing hazards when the codes and standards used for existing equipment are outdated and no longer describe good engineering practice.<\/li>\n<\/ol>\n<p style=\"text-align: justify;\">Employers\u2019 internal standards must either meet or exceed the protective requirements of published RAGAGEP where such RAGAGEP exist. \u00a0OSHA has rejected employer standards that deviated from published RAGAGEP where the deviations were less protective than the published requirements.<\/p>\n<p style=\"text-align: justify;\"><strong>\u201cShall\u201d and \u201cShould\u201d in RAGAGEP<\/strong><\/p>\n<p style=\"text-align: justify;\">\u201cShall,\u201d \u201cmust,\u201d or similar language used in published RAGAGEP reflects the developer\u2019s view that the practice is a mandatory minimum requirement to control a hazard. \u00a0Similarly, \u201cshall not,\u201d \u201cprohibited,\u201d or similar language references or describes unacceptable approaches or practices. \u00a0If an employer deviates from \u201cshall\u201d or \u201cshall not\u201d requirements in the employer\u2019s adopted RAGAGEP (or applicable RAGAGEP if the employer has not specified RAGAGEP), OSHA will presume a violation.<\/p>\n<p style=\"text-align: justify;\">Use of the term \u201cshould\u201d or similar language in the RAGAGEP reflects an acceptable and preferred approach, in the view of the publishing group, to controlling a recognized hazard. \u00a0If a selected RAGAGEP provision is applicable to the covered process or particular situation, OSHA presumes that employer compliance with the recommended approach is acceptable.<\/p>\n<p style=\"text-align: justify;\"><span style=\"text-decoration: underline;\">If an employer chooses to use an alternate approach to the one the published \u201cshould\u201d RAGAGEP says applies, the CSHO should evaluate whether the employer has determined and documented that the alternate approach is at least as protective<\/span>, or that the published RAGAGEP is not applicable to the employer\u2019s operation.\u00a0 <span style=\"text-decoration: underline;\">In the absence of such documentation, the CSHO should examine documents, such as relevant process hazards analyses (PHAs) and management of change procedures (MOCs), to determine if the employer\u2019s approach is as protective as the published RAGAGEP and is a good engineering practice.<\/span> This may require consultation with Regional resources or the OSHA National Office (see below).<\/p>\n<p style=\"text-align: justify;\">\u201cShould not\u201d or similar language describes disfavored or less than fully protective practices. \u00a0Following such disfavored practices is presumed to be violative.<\/p>\n<p style=\"text-align: justify;\">For technical help, consult with your Regional PSM Coordinator, technical support engineer, or contact the PSM group at OSHA\u2019s Directorate of Enforcement Programs &#8211; Office of Chemical Process Safety and Enforcement Initiatives at 202-693-2341.<\/p>\n<p style=\"text-align: justify;\"><strong>\u201cNormative\u201d and \u201cInformative\u201d Requirements.<\/strong><\/p>\n<p style=\"text-align: justify;\">Published codes and consensus documents frequently contain appendices or annexes that provide supplemental information and\/or requirements.\u00a0 The content of these appendices or annexes may be \u201cnormative\u201d or \u201cinformative.\u201d\u00a0 \u00a0\u201cNormative\u201d sections generally explain how to comply with the published code and\/or consensus document requirements and may contain both \u201cshall\u201d and \u201cshould\u201d language. \u00a0As discussed above, \u201cshall\u201d denotes the developer\u2019s view that the normative statement is mandatory, while \u201cshould\u201d indicates an acceptable or preferred approach. \u00a0\u201cInformative\u201d sections generally provide background and reference information with respect to the published code and\/or consensus document requirements but may also identify and\/or address hazards or acceptable means of abatement. Again, for technical help, CSHOs should consult their Regional PSM coordinator, technical support engineer, or the Office of Chemical Process Safety and Enforcement Initiatives.<\/p>\n<p style=\"text-align: justify;\"><strong>Other Uses of RAGAGEP Materials in PSM<\/strong><\/p>\n<p style=\"text-align: justify;\"><span style=\"text-decoration: underline;\">Only the three sections of 1910.119 referenced above require compliance with RAGAGEP.<\/span> However, RAGAGEP can also provide useful background and context, and can help CSHOs identify and document hazards and feasible means of abatement when reviewing other aspects of the employer\u2019s PSM program and covered equipment.<\/p>\n<p style=\"text-align: justify;\"><strong>Enforcement considerations<\/strong><\/p>\n<p style=\"text-align: justify;\">In accordance with 1910.119, employers select the RAGAGEP with which their equipment and procedures must comply.\u00a0 In evaluating RAGAGEP compliance, CSHOs should be aware of a number of potential issues:<\/p>\n<ol style=\"text-align: justify;\">\n<li><span style=\"text-decoration: underline;\">There may be multiple RAGAGEP that apply to a specific process.<\/span> \u00a0For example, American Petroleum Institute (API), RP 520 <em>Sizing, Selection, and Installation of Pressure-Relieving Devices in Refineries Part II &#8211; Installation<\/em>, and International Standards Organization, Standard No. 4126-9, \u00a0<em>Application and installation of safety devices<\/em>, are both RAGAGEP for relief valve installation and contain similar but not identical requirements. \u00a0Both documents are protective and either is acceptable to OSHA.<\/li>\n<li><span style=\"text-decoration: underline;\">Employers do not need to consider or comply with a RAGAGEP provision that is not applicable to their specific worksite conditions, situations, or applications.\u00a0<\/span><\/li>\n<li>Some employers apply RAGAGEP outside of their intended area of application, such as using ammonia refrigeration pressure vessel inspection recommended practices in a chemical plant or refinery process.\u00a0 Use of inapplicable RAGAGEP can result in poor hazard control and can be grounds for citations.<\/li>\n<li><span style=\"text-decoration: underline;\">There may be cases where fully applicable RAGAGEP do not exist to control hazards in an employer\u2019s covered process.\u00a0<\/span> As discussed in \u201cAppropriate Internal Standards\u201d, above, the employer\u2019s internal standards (guidance and procedures) are expected to address the process hazards. \u00a0Whether the internal standards are adequately protective should be reviewed on a case-by-case basis.<\/li>\n<li>An employer\u2019s internal standards may be more stringent than the relevant published RAGAGEP.\u00a0 More-stringent standards may be needed to adequately control hazards due to the unique characteristics of the employer\u2019s process.\u00a0 This should be documented.\u00a0 <span style=\"text-decoration: underline;\">Employers that meet published RAGAGEP requirements, but that fail to comply with their own more stringent internal requirements, may be citable under other PSM provisions:<\/span>\n<ul>\n<li><span style=\"text-decoration: underline;\">If there is a failure to follow more stringent internal Inspection &amp; Test (I&amp;T) procedures, consider citations under 1910.119(j)(2) for failure to implement their written I&amp;T procedures<\/span><\/li>\n<li><span style=\"text-decoration: underline;\">Process equipment may be outside acceptable limits defined in the employer\u2019s PSI.\u00a0 If so, consider citations under 1910.119(j)(5).<\/span><\/li>\n<li><span style=\"text-decoration: underline;\">Additional or more stringent equipment safeguards may be specified by employers based on findings and recommendations from PHAs and supporting documents, such as Layers of Protection Analyses, siting studies, human factors studies, Quantitative Risk Assessments, and similar risk management activities, as well as Incident Investigations, or Management of Change procedures. Failure to implement or complete documented actions-to-be-taken may be cited under the relevant section of the Standard (e.g., 1910.119(e), (l), or (m)).<\/span><\/li>\n<\/ul>\n<\/li>\n<li><span style=\"text-decoration: underline;\">Selectively applying individual provisions from multiple RAGAGEP addressing similar hazards might be inappropriate. \u00a0Standard writing organizations develop their requirements as packages and mixing-and-matching provisions from multiple sources could result in inadequately controlled hazards.<\/span> \u00a0This situation should be evaluated on a case-by-case basis. Consult the regional PSM Coordinator, regional engineering support, or the Office of Chemical Process Safety and Enforcement Initiatives if you are uncertain how to proceed.<\/li>\n<li>The PSM standard requires employers to document that their inspection and testing of equipment, required under 1910.119(j)(4)(ii) and (iii), is in accordance with their selected RAGAGEP, (<em>e.g.,<\/em> as referenced in the written procedures required by 1910.119(j)(2)). \u00a0Failure to do so is citable.<\/li>\n<li>In accordance with 1910.119(d)(3)(ii), employers must document that their covered process equipment and equipment whose operation could affect that process equipment comply with RAGAGEP (equipment built to older standards may come under 1910.119(d)(3)(iii), see paragraph 10 below). \u00a0<span style=\"text-decoration: underline;\">Equipment that does not comply with RAGAGEP cannot be documented as compliant. \u00a0Therefore, both the failure to document compliance and the deviations from compliance with RAGAGEP can be cited under (d)(3)(ii).<\/span>\n<p><span style=\"text-decoration: underline;\">When writing 1910.119(d)(3)(ii) RAGAGEP-related citations, always cite the employer for <strong>failing to document<\/strong> compliance with recognized and generally accepted good engineering practices, describe the hazard, e.g., exposure of employees to fire, explosion, or toxic hazards, and reference the RAGAGEP selected by the employer.\u00a0 If the employer has not specified an applicable RAGAGEP, use \u201csuch as\u201d language to reference an applicable published RAGAGEP.<\/span><\/li>\n<li>Equipment covered under PSM\u2019s Mechanical Integrity provisions (listed in 1910.119(j)) that is outside acceptable limits, as defined by the process safety information (including RAGAGEP), is deficient under 1910.119(j)(5). \u00a0Employers are required by this provision to correct deficiencies before further use or in a safe and timely manner when necessary means are taken to assure safe operation in the interim.\u00a0 If an employer fails to correct the deficiency before further use, or fails to implement adequate interim measures and to schedule a permanent correction timely, the failure may be cited under 1910.119(j)(5).\u00a0 <span style=\"text-decoration: underline;\">If an employer has implemented interim measures and scheduled correction, additional investigation may be required to determine whether the interim measures are adequate and the scheduled correction is timely.<\/span> 1910.119(d)(3)(ii) and (j)(5) citations are often grouped. \u00a0Consult your Regional OSHA support staff and\/or SOL if you are uncertain if grouped citations are appropriate.\n<p><span style=\"text-decoration: underline;\"><strong>Note, in the case where an employer is operating deficient equipment based on the use of interim safeguards pending final correction of the deficiency, 29 CFR 1910.119(l) requires that the employer develop and implement a management-of-change procedure for the continued safe operation of the equipment.<\/strong><\/span><\/li>\n<li><span style=\"text-decoration: underline;\">Older covered equipment may not have been designed and constructed under an applicable RAGAGEP because none existed at the time of design and construction. Alternatively, the equipment may have been designed and constructed under provisions of codes, standards, or practices that are no longer in general use.\u00a0 In such cases, 29 CFR 1910.119(d)(3)(iii) requires employers to determine and document that the equipment is designed, maintained, inspected, tested, and operating in a safe manner. \u00a0Failure to do so may be cited under 1910.119(d)(3)(iii).<\/span>\n<p><span style=\"text-decoration: underline;\">When writing 1910.119(d)(3)(iii) citations, always cite the employer for <strong>failing to determine and document <\/strong>that the relevant equipment design, maintenance, inspection and testing, and\/or operation ensure the safety of the equipment.<\/span><\/p>\n<p>If the employer has adopted an appropriate internal standard applicable to such older equipment, 29 CFR 1910.119(d)(3)(ii) requires the employer to document that the equipment complies with the internal standard.\u00a0 Failure to do so may result in a citation under 29 CFR 1910.119(d)(3)(ii).<\/li>\n<li>When a 29 CFR 1910.119(d)(3)(ii) or (iii) citation is under consideration, it is important to establish and to document the age and installation date of the relevant process and equipment, and the dates and extent of process and equipment modifications, as well as the exact RAGAGEP selected by the employer, including the edition and publication date.<\/li>\n<li>Organizations that publish RAGAGEP may update them based on newly identified or recognized hazards; improved understanding of existing hazards; industry operating experience; and\/or incidents indicating that more stringent hazard control is needed. If the updated RAGAGEP explicitly provides that new clauses or requirements are retroactive, OSHA expects employers that have selected that RAGAGEP to conform to those provisions. <span style=\"text-decoration: underline;\">Where RAGAGEP are updated to be more protective but are not explicitly retroactive, PSM does not mandate that employers upgrade their equipment, facilities, or practices to meet current versions of their selected RAGAGEP.\u00a0 However, OSHA does expect employers to address issues raised by or identified in the updated RAGAGEP in accordance with 1910.119(d)(3)(iii) by determining and documenting that their equipment is designed, maintained, inspected, tested, and operating in a safe manner. This can be accomplished through a variety of approaches, such as but not limited to the PHA revalidation and management of change (MOC) processes, or through corporate monitoring and review of published standards.<\/span> Citations for 29 CFR 1910.119(d)(3)(iii), either stand-alone or grouped with, for example, (e)(3) or (l)(1), may be appropriate if the employer fails to address the issues (see item 8 above).<\/li>\n<li>Notify the Office of Chemical Process Safety and Enforcement Initiatives if you encounter RAGAGEP that appear to have changed to be less protective or that are being interpreted by employers in a manner that is less protective. In the past, OSHA determined that specific provisions in published guidance documents were not RAGAGEP (i.e., OSHA believed that some written practices provided inadequate protection and were not good engineering practices; therefore, the specific practices in question could not be RAGAGEP). \u00a0Such determinations should only be made in consultation with the Office of Chemical Process Safety and Enforcement Initiatives.<\/li>\n<li>When writing 1910.119(j)(4)(ii) citations, always cite the employer for failing to follow RAGAGEP in its inspection and testing procedures, and reference the relevant RAGAGEP adopted \/ recognized by the employer.\u00a0 If the employer has not specified an applicable RAGAGEP, use \u201csuch as\u201d language to reference an applicable published RAGAGEP. \u00a0When the employer\u2019s I&amp;T procedures comply with RAGAGEP, but are not implemented or followed, consider 1910.119(j)(2) citations.<\/li>\n<li><span style=\"text-decoration: underline;\">When writing 1910.119(j)(4)(iii) citations, always cite the employer for not inspecting and\/or testing process equipment at frequencies <strong>consistent<\/strong> with applicable manufacturers\u2019 recommendations and good engineering practices, <strong>or more frequently<\/strong> if indicated by prior operating experience, i.e., based on the condition of the equipment when previously inspected or tested.<\/span><\/li>\n<li>When writing RAGAGEP-related citations when the employer has not specified a RAGAGEP, CSHOs should be careful to reference in the citation\u2019s alleged violation description only RAGAGEP that are actually applicable to the equipment and process being inspected.\u00a0 <span style=\"text-decoration: underline;\">CSHOs have sometimes referenced inapplicable API relief valve RAGAGEP in citations involving ammonia refrigeration processes.<\/span><\/li>\n<\/ol>\n<p style=\"text-align: justify;\">\n","protected":false},"excerpt":{"rendered":"<p>Link to OSHA publication\u00a0&#8211; Highlights (underline) are mine. Note that they reference the CCPS\u00a0again. The really good stuff is at the bottom in the notes to the inspectors. &nbsp; MEMORANDUM FOR: REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNEES THROUGH: DOROTHY DOUGHERTY &hellip; <a href=\"https:\/\/taocompliance.com\/?p=770\">Continue reading <span class=\"meta-nav\">&rarr;<\/span><\/a><\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_monsterinsights_skip_tracking":false,"footnotes":""},"categories":[8,40,65],"tags":[15,66,9,10,21],"class_list":["post-770","post","type-post","status-publish","format-standard","hentry","category-compliance","category-nep","category-osha","tag-fines","tag-nep","tag-osha","tag-psm","tag-ragagep"],"_links":{"self":[{"href":"https:\/\/taocompliance.com\/index.php?rest_route=\/wp\/v2\/posts\/770","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/taocompliance.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/taocompliance.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/taocompliance.com\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/taocompliance.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=770"}],"version-history":[{"count":2,"href":"https:\/\/taocompliance.com\/index.php?rest_route=\/wp\/v2\/posts\/770\/revisions"}],"predecessor-version":[{"id":772,"href":"https:\/\/taocompliance.com\/index.php?rest_route=\/wp\/v2\/posts\/770\/revisions\/772"}],"wp:attachment":[{"href":"https:\/\/taocompliance.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=770"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/taocompliance.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=770"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/taocompliance.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=770"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}