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Posted by / 17-Jan-2018 04:38

Good engineering practice of updating facilities

RAGAGEP plays a central role for operators as they evaluate the ongoing use and operation of equipment.

OSHA's enforcement of this term — which is not defined — has...

Law360, New York (June 24, 2015, AM EDT) -- As employers familiar with the process safety management (“PSM”) standard are aware, the U. Occupational Safety and Health Administration’s shifting enforcement of its regulations can at times pose significant compliance challenges.

Perhaps no other aspect of the PSM standard exemplifies this challenge more than the requirements to comply with recognized and generally accepted good engineering practices ("RAGAGEP").

The answers to the questions have been derived from provisions of Education Law, Commissioner's Regulations and Rules of the Board of Regents and administrative decisions made by the State Education Department.

While they reflect provisions of Law, Regulation and interpretations, the legal application will depend upon the facts of a particular situation.

After the Chevron Richmond Refinery incident in 2012, a massive fire that sent hundreds of people rushing to hospitals and pushed West Coast gas prices higher, the U. Chemical Safety Board, the federal Occupational Safety and Health Administration (OSHA), and state agencies have increased their process safety management (PSM) recommendations and enforcement efforts. All facilities that fall under OSHA’s Refinery NEP, as well as state equivalents to the Refinery NEP (CPL 03-00-010), will be affected by the Federal OSHA issued memorandum defining “recognized and generally accepted good engineering practices” (RAGAGEP) for its inspectors, and detailing how RAGAGEP should be used in PSM enforcement. Keep reading to learn the definition of RAGAGEP, what documents meet OSHA’s criteria for RAGAGEP, and how inspectors will select and apply RAGAGEP during an inspection.

This information is intended to provide general guidance to those who may have questions about licensing or professional conduct.

If you are reading this article, I’m sure that you are most interested in knowing how inspectors will apply RAGAGEP during an inspection so as to avoid unnecessary citations and fines.

Inspectors can use a RAGAGEP document to assist in an inspection, but they must follow OSHA’s guidelines while doing so.

Under this scenario they would need to obtain a home inspection license.

Note: There are a finite group of general business corporations that were in existence and providing professional engineering services on April 15, 1935, and continuously thereafter, and were lawfully engaged in the practice of professional services in New York State.

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