PSM RAGAGEP Enforcement Policy Revised May 2016
In May 2016, OSHA issued a new Letter of Interpretation for the Process Safety Management (PSM) standard's Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) requirements originally outlined in the PSM Standard (29 CFR 1910.119). OSHA notes that this “memorandum rescinds and replaces the memorandum of the same title dated June 5, 2015.” It is intended to clarify OSHA’s policy but does not include any substantive changes to their enforcement policy related to RAGAGEPs.
OSHA does a good job of adding details into the policy that we as practitioners have known for quite some time. The details provided help make things clear. There is a lot of good information in the revised policy. I just want to touch on a few things here.