A common question posed during compliance audits and training is “what exactly is Recognized And Generally Accepted Good Engineering Practices (RAGAGEP) and how do we determine what is the appropriate RAGAGEP for our PSM covered process?” In this series of articles or posts, I will attempt to answer some of the more prominent questions and misconceptions regarding this important part of the PSM regulation. In the first part of this series, we will look at what is RAGAGEP. In subsequent parts, we will review some of the pitfalls, or concerns, with some industry RAGAGEP(s), how we go about determining the most appropriate RAGAGEP(s) for our facility, PSM regulatory requirements for selecting design codes & standards, misconceptions regarding application of RAGAGEP, and finally discuss RAGAGEP(s) for maintaining equipment in the covered process.

First, what is RAGAGEP? In various industries, there are typically groups of individuals with significant knowledge and experience that formally get together to collaborate and/or share “best practices” on how to manufacture, construct/build, and maintain equipment or systems that are common in their processes. These groups then document and publish their collaborative work and allow for peer review, feedback, and comments on the published work or best practices. The group will then incorporate any peer input/feedback that the consensus group determines is appropriate and what will appear in the final published document to be shared with industry as a whole. This published document then may be used as a guided engineering and operations standard for anyone in the same industry, or that may operate the same type of equipment, therefore they can take advantage of this collective knowledge to improve the facility process safety. This published work, is what is known as a specific industry Code & Standard or RAGAGEP, and what we may often refer to as a “consensus standard”. Consensus meaning that industry representatives by consensus decide how and what are the best methods to use to manufacture, construct/build, maintain, etc. some equipment of device or entity. Not all industries have a complete set of consensus standards that fit their specific industry. In fact, some of the consensus standards used today were non-existent when the PSM regulation was promulgated or went into effect. This is in fact, one of the reasons the PSM regulation was developed and promulgated as a “performance” standard.

In part 2 of this series, we will discuss a few pitfalls in some of the RAGAGEPs, and why it is important to get the correct knowledge and experience within these codes & standard groups to further enhance the desired goal of improved process safety.