RAGAGEP: Codes, Standards, and Good Engineering Practices (Part 7)

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. This is the seventh in a series of blogs which include excerpts from his technical paper. The previous blogs are available in the following links: Part 1, Part 2, Part 3, Part 4, Part 5, and Part 6.

Consideration of New RAGAGEPs

The previous section helped clarify how RAGAGEPs apply to facilities that have been built or modified in phases over several years. What about the hypothetical facility that was built decades ago and has not been modified since? The following sections will address how such a facility should respond to new and changing RAGAGEPs which were not applicable on the date of original design and installation.

Role of Process Safety Information

Facilities subject to PSM are required to document that “equipment complies with recognized and generally accepted good engineering practices” (Title 29 §1910.119(d)(3)(ii)). While this does not translate to modifying the system for every code change, it does require acknowledgement that codes and standards are consensus documents that represent the general opinion of a specific industry. Therefore, while a single code change may not be significant, if that code change becomes a perpetual requirement in consecutive code cycles, it may eventually become enforceable RAGAGEP. For example, the UMC did not require ammonia detection for machinery rooms until 1994. Facilities built prior to that date would not have been expected to have ammonia detection as part of the system installation. Since 1994, the UMC has required ammonia detection in eight consecutive releases of the document. The consistent inclusion of ammonia detection as a requirement in the UMC and all other codes/standards makes ammonia detection a prime example of RAGAGEP. In other words, an ammonia refrigeration system which is not equipped with ammonia detection would not comply with RAGAGEP regardless of the age of the system.

Role of the Process Hazard Analysis

Every five years, facilities subject to PSM are required to perform or revalidate their Process Hazard Analysis (PHA). While it is beyond the scope of this paper to discuss PHAs in depth, the following PHA requirements (emphasis mine) are worth special consideration:

• The process hazard analysis shall address the identification of any previous incident which had a likely potential for catastrophic consequences in the workplace.
• The process hazard analysis shall be performed by a team with expertise in engineering and process operations.

As previous incidents are analyzed during a PHA study, it is a natural progression for RAGAGEP changes to be considered. For example, if a contributing cause of a previous incident was inadequate access to ventilation controls, it would be appropriate for the PHA to consider (and possibly recommend) that the ventilation system controls be upgraded to meet the current requirements for remote ventilation controls.

Additionally, since the PHA is required to be performed by a team which includes engineering expertise, it is expected that the PHA would include consideration of the latest engineering innovations and best practices.

Role of Mechanical Integrity

Mechanical Integrity (MI) is a cornerstone element of PSM which requires regular inspections and tests of process equipment. As was previously stated, MI inspection procedures and frequency must comply with RAGAGEP. Over the course of time, it is to be expected that MI inspections and tests will reveal deficiencies which require repair or replacement. When components require repair or replacement, this provides a good opportunity to consider the most current RAGAGEPs rather than the RAGAGEPs that were in place at the time of initial design and installation.

Conclusion

Navigating the realm of “recognized and generally accepted good engineering practice” can be challenging due to the transient nature of code documents. Having a proper understanding of the organizations and documents that represent industry-specific RAGAGEP is essential to demonstrating compliance with RMP and PSM. While it is acknowledged that conflicts still exist, the trajectory of ammonia refrigeration RAGAGEP is pointed toward IIAR as the premier standard writing organization and IIAR’s suite of standards as the primary RAGAGEPs for this industry. This is a welcomed direction, as it allows ammonia refrigeration best practices to be shaped by the experts within their industry.