RAGAGEP: Codes, Standards, and Good Engineering Practices (Part 1)

Peter Thomas, P.E. recently wrote a technical paper and presented at the 2017 RETA National Conference on the topic of RAGAGEP: Codes, Standards, and Good Engineering Practices. The next few blogs will include excerpts from his technical paper.

Introduction

The arena of codes, standards, and regulations can be confusing, frustrating, and often intimidating. The barrage of acronyms: IMC, UMC, IFC, ASHRAE, IIAR, etc. can stump even a seasoned engineer trying to answer the simple question, “What am I required to do?”.  To complicate matters, model codes and standards are regularly revised, often on a three-year cycle, which causes many to feel as though they are trying to hit a moving target. It is the intention of this paper to attempt to bring clarity to the topic of “recognized and generally accepted good engineering practices” (RAGAGEP) for the ammonia refrigeration industry by providing an overview of codes, standards, and practices that make up the core of RAGAGEP. Emphasis will be placed on the International Institute of Ammonia Refrigeration’s (IIAR) suite of standards which address minimum best practices for all aspects of ammonia refrigeration systems from initial design until final decommission. Additionally, this paper will attempt to address the following important RAGAGEP issues:

• Model Codes and Standards Applicable to Ammonia Refrigeration
• RAGAGEP Conflicts
• Grandfathering
• Addressing New RAGAGEPs

Regulatory Basis

Both the USEPA’s Risk Management Program (Title 40 §68) and OSHA’s Process Safety Management regulation (Title 29 §1910.119) are “performance-based” standards. This means that the government has defined “what must be done”, but has not specified “how to do it”. As a result, best practices for RMP-PSM implementation vary greatly between industries. The performance-based nature of RMP-PSM is best seen in the references to “good engineering practice” and “recognized and generally accepted good engineering practice” which are used in, and throughout both regulations:

Risk Management Program (RMP) RAGAGEP References

• Title 40 §68.65(d)(2) Process Safety Information
  The owner or operator shall document that equipment complies with recognized and generally accepted good engineering practices.
• Title 40 §68.73(c)(2) Mechanical Integrity
  Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.
• Title 40 §68.73(c)(2) Mechanical Integrity
  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.

Process Safety Management (PSM) RAGAGEP References

• Title 29 §1910.119(d)(3)(ii) Process Safety Information
  The employer shall document that equipment complies with recognized and generally accepted good engineering practices.
• Title 29 §1910.119(j)(4)(ii) Mechanical Integrity
  Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.
• Title 29 §1910.119(j)(4)(iii)) Mechanical Integrity
  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.

Additionally, both PSM and RMP require that the “information pertaining to the equipment in the process shall include: Design codes and standards employed” (Title 29 §1910.119(d)(3)(i)(F), Title 40 §68.65(d)(vi)). “Design codes” and “standards” are documents which address “good engineering practices” within the scope of the document. As such, “design codes and standards” are synonymous to RAGAGEP in the remainder of this paper.

RAGAGEP Regulatory Citations

This emphasis on RAGAGEP in RMP-PSM has resulted in a heightened importance on model codes, standards, and other industry literature. Both OSHA and EPA have used the RAGAGEP references contained within industry documents as the basis of RMP-PSM citations. Appendix A includes details from five separate instances of ammonia refrigeration facilities receiving OSHA citations for failure to comply with RAGAGEP. The citations are intended to demonstrate how RAGAGEP documents are used by government agencies during inspections.