Both PSM and RMP require that the owner or operator have a system in place to promptly address the team’s PHA findings and recommendations to assure they are resolved in a timely matter. See 29 CFR 1910.119(e)(5) and 40 CFR 68.67(e). In accordance with Pre-startup review requirements, these PHA recommendations must be resolved or implemented
What is RAGAGEP?
By Kean Miller on
Posted in Process Safety Management
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…
How Much Time Do I Have to Implement an Accepted Recommendation?
By Kean Miller on
Posted in Process Safety Management
After the team makes a recommendation, the first step is to resolve the team’s finding. If the resolution is to accept the recommendation, the employer must complete the actions as soon as possible. See 29 CFR 1910.119(e)(5).
OSHA expects that accepted recommendation be completed as soon as possible which usually means with one to…
How do I Know Which Applies to Me, PSM or RMP?
By Kean Miller on
Posted in Process Safety Management
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…