Process Safety Management

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RAGAGEP is an acronym for the term “Recognized and Generally Accepted Good Engineering Practice.” Although this term is not defined in the PSM or RMP regulations, it is found within the Process Safety Information (PSI) and Mechanical Integrity sections. Significant controversy exists around the term and its meaning resulting, in part, in recent…

Both PSM and Program 3 of RMP require compliance with similar elements which include the:

  • accumulation of process safety information (“PSI”),;
  • some type of hazard analysis (“PHA”);
  • operating procedures;
  • training, mechanical integrity (“MI”);
  • management of change (“MOC”);
  • pre-startup reviews (“PSR”);
  • compliance audits;
  • incidents investigations;
  • employee participation

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There is only one level of PSM applicability; either you are in or out. Processes are subject to PSM if they contain the threshold amount of a Chemical found in Appendix A to the rule, or if it has more than 10,000 pounds of a flammable gas or liquid. See 29 CFR 1910.119(a). PSM applicability…