2025 Spring Meeting and 21st Global Congress on Process Safety

(41ai) Ragagep Emphasis

Authors

Neil Prophet - Presenter, Iomosaic Corporation
Anna Shinkawa, ioMosaic
RAGAGEP, or Recognized and Generally Accepted Good Engineering Practices; is an important concept within process safety and is a requirement of both the OSHA Process Safety Management (PSM) Standard and EPA Risk Management Program (RMP) rule.

The concept is applied to both Process Safety Information, and Mechanical Integrity; requiring that equipment complies with recognized and generally accepted good engineering practices; and that equipment is also inspected and tested following recognized and generally accepted good engineering practices at an appropriate frequency.

The issue of what constitutes RAGAGEP has been widely debated, and as a response OSHA issued a standard interpretation titled, “RAGAGEP in Process Safety Management Enforcement” providing four examples of RAGAGEP: (1) Widely adopted codes (2) Consensus documents (3) Non-consensus documents, and (4) Internal Standards. Additionally, other organizations have provided their own definitions and interpretations.

With the recent EPA RMP updates, RAGAGEP is again a hot topic, with the requirement that the Process Hazard Analysis must address any gaps in safety between the codes, standards, or practices to which the process was designed and constructed; and the most current version of applicable codes, standards, or practices.

This paper discusses the concept of RAGAGEP, enforcement considerations, appropriate RAGAGEP sources and relevant codes and standards. It also offers guidance on the RAGAGEP gap analysis requirement.