Responding to Changes in RAGAGEP
Codes and standards change frequently. Many organizations operate on cycles in which their codes or standards are updated at least every three (3) years. This constant change can present challenges to business owners and operators who desire to be “compliant”, but don’t have endless time or money to stay on top of every code change.
The PSM regulation requires that a facility document the codes and standards that were (and are) adhered to at their facility. This requirement relates to design, installation, operation, and maintenance. In several instances the phrase “recognized and generally accepted good engineering practice” (RAGAGEP) or simply “good engineering practice” is used within the PSM regulation in regard to the requirements for process equipment. Typically, a facility will use a code or standard in order to document that a process complies with RAGAGEP. The following list summarizes the instances in PSM where code, standard, or RAGAGEP is mentioned:
- 29 CFR §1910.119(d)(3)(i)(F) Information pertaining to the equipment in the process shall include design codes and standards employed
- 29 CFR §1910.119(d)(3)(ii) The employer shall document that equipment complies with recognized and generally accepted good engineering practices.
- 29 CFR §1910.119(j)(4)(ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.
- 29 CFR §1910.119(j)(4)(iii) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers’ recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.
We have written and presented on the topic of RAGAGEP in the past, but never explicitly in addressing what to do when a new RAGAGEP is developed or an existing RAGAGEP is updated. We are often faced with the following hypothetical question:
My facility was built according to code at the time of construction, but since then the code has changed to include additional requirements that we have not installed or implemented at our facility. Do I have to upgrade my facility to the most current code requirements in order to be ‘compliant’?
The answer to this hypothetical question is “No”. In general, codes and standards are intended to apply to new installations and expansions to existing systems. The requirements contained within new RAGAGEP documents are not intended to be viewed as “requirements” for existing installations. If a facility desires to enhance an existing system that is installed in accordance with a legacy code or standard (historical RAGAGEPs), it is acceptable to bring select areas of their existing facility/system up to the current requirements without upgrading the entire facility or system. In this situation, the facility would be exceeding their RAGAGEP requirements for the areas that were upgraded. It is worth noting that both PHAs and mechanical integrity inspections are excellent opportunities to review the most current RAGAGEPs and to consider potential upgrades and improvements.
IIAR is developing a new standard (IIAR 9) which will help define the minimum requirements for existing refrigeration systems (RAGAGEP Standard). This new standard is on track to be published next year.