Mastering Process Safety Management: Are you RAGAGEP Compliant?

Over 200 hazardous chemical incidents, including fires, explosions and harmful releases have happened in the USA this year alone. Process Safety Management (PSM) / Risk Management Plans (RMP) in industrial projects are critical to prevent highly hazardous chemical releases that pose threats and harm to employees, the public, or the environment. PSM/RMP can help in forming a critical framework, managing risk and ensuring compliance, but how do companies plan to comply with Recognized and Generally Accepted Good Engineering Practices (RAGAGEP)?

What is RAGAGEP?

RAGAGEP (Recognized and Generally Accepted Good Engineering Practices) provide the basis for engineering, operation, and maintenance activities and are themselves based on established codes, standards, published technical reports, recommended practices (RP), or similar documents. RAGAGEP detail generally accepted ways to perform specific engineering, inspection, and mechanical integrity activities. These practices are derived from:

• Published codes and standards (e.g., from bodies like the American Society of Mechanical Engineers (ASME) or National Fire Protection Association (NFPA),
• Manufacturer provided information and directions, and
• Industry consensus documents.

While the concept of RAGAGEP sounds straightforward, it can be difficult for organizations to pinpoint exactly which standards apply to their operations and how to maintain compliance over time. This challenge often becomes a major stumbling block in achieving and sustaining compliant process safety management programs.

The RAGAGEP Compliance Challenge

There are several reasons why identifying and assuring compliance with RAGAGEP can be so difficult:

• Constantly Evolving Standards: Industry codes and standards are regularly updated to reflect new technologies, materials, and safety learnings. Keeping up with these changes and applying the appropriate version of the standard to your operations is critical but resource-intensive.
• Ambiguity and Overlap: Different sources of RAGAGEP—whether from industry bodies, or manufacturer information—can sometimes conflict or overlap. Deciding which standard takes precedence can create confusion, especially if a company operates in multiple sectors or jurisdictions with varying regulations.
• Documentation and Justification: Even if you have identified the appropriate RAGAGEP, documenting your decisions and justifying your approach to regulators can be a complex process. You must demonstrate that your practices are in line with industry norms, especially when deviations or alternative methods are applied.

Staying Process Safety Management Compliant with RAGAGEP

While these challenges may seem daunting, a structured approach can help organizations navigate the complexities of RAGAGEP compliance and ensure their process safety management programs are robust and effective.

• Develop a RAGAGEP Framework: The first step is to establish a systematic framework for identifying, reviewing, and applying RAGAGEP within your organization. Your comprehensive list of the RAGAGEP for all of your systems and equipment should include regularly monitoring updates to relevant standards and ensuring they are integrated into your processes. Assigning a dedicated team or individual to manage this process can help maintain accountability.
• Conduct a Gap Assessment and Periodically Update: One of the best ways to ensure ongoing compliance with RAGAGEP is to conduct an initial detailed gap assessment and then to periodically update that gap assessment. This should include a thorough review of engineering practices, maintenance procedures, and operating standards to verify that they are consistent with current RAGAGEP. Gap assessments can also provide an opportunity to identify any areas where your practices may be falling behind or where conflicts between different RAGAGEP sources might arise.
• Leverage External Expertise: In some cases, it may be necessary to bring in external experts to review your systems and help identify the most appropriate standards. Industry consultants can offer a fresh perspective on your processes, ensuring that all potential gaps in compliance are identified and addressed. They can also provide guidance on how to handle conflicting standards and offer solutions for integrating RAGAGEP into your PSM/RMP program.
• Documentation and Training: Clear documentation is essential to demonstrating compliance with RAGAGEP. This includes not only maintaining up-to-date procedures and standards, but also providing a clear rationale for why certain practices have been adopted. Training employees on RAGAGEP requirements and the importance of compliance is also crucial, ensuring that everyone from operators to engineers is aligned with best practices.

Achieve RAGAGEP Compliance with Montrose

Ensuring compliance with RAGAGEP is one of the most challenging aspects of implementing an effective PSM/RMP program, but it is essential for maintaining operational safety and meeting regulatory requirements.
At Montrose, we understand those complexities and take a proactive, structured approach to identifying and applying RAGAGEP to process safety management programs. We can help your company avoid costly penalties, reduce risks, and enhance overall process safety. Our team of experienced professionals can help your organization by:

• Conducting or updating a Gap Assessment: We’ll work with you to identify any areas where your current practices may fall short of RAGAGEP requirements, providing actionable recommendations for improvement.
• Providing RAGAGEP Expertise: Our consultants stay up-to-date on the latest industry codes, standards, and practices to ensure your organization is compliant with the most current RAGAGEP applicable to your operations.
• Streamlining Documentation: We help develop clear, concise documentation that not only meets regulatory requirements but also simplifies internal communication and decision-making regarding PSM/RMP compliance.
• Training and Competence Building: We provide tailored training programs to ensure your employees are fully aware of RAGAGEP standards and understand how to apply them in day-to-day operations.

If your organization is facing challenges related to RAGAGEP compliance, contact our EHSS Consulting team today. We can help you establish a PSM program that not only meets industry standards but also provides a safer and more efficient operating environment.