RAGAGEP Gap Analysis for Ammonia Facilities
OSHA first introduced the concept of Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) in their PSM standard, CFR 1910.119. Engineers and operators need to make every effort to follow established good engineering practices when designing and maintaining process equipment. A RAGAGEP Gap Analysis analyzes the as-built process conditions and suggests potential additional mitigation measures based on current applicable industry best practices, codes and standards for the covered process to improve facility safety. The RAGAGEP Gap Analysis is meant to:
- verify that the existing RAGAGEP standards employed at the facility follow applicable industry guidelines;
- verify adequacy of implementation (e.g. maintenance program, safety features, etc.);
- identify industry best practices (e.g., latest RAGAGEP codes & standards, recommended practices employed at similar facilities);
- compare the existing system and design in place at the facility with RAGAGEP standards, including International Institute of Ammonia Refrigeration (IIAR), American National Standards Institute (ANSI), American Petroleum Institute (API), American Society of Mechanical Engineers (ASME), American Society of Testing Materials (ASTM), etc.
RAGAGEP Gap Analyses do not directly satisfy regulatory requirements, unless it is used to satisfy the RAGAGEP portion of the PSI section requirements outlined in the CalARP/RMP/PSM regulations, in which case it would be subject to regulatory scrutiny at the discretion of the regulating agency.