The Value of Maintaining RAGAGEP Documentation With a Digital Solution

While the use of engineering standards for designing and maintaining equipment pre-dates regulatory requirements, the industry agrees that the American Petroleum Institute (API) set a precedent in 1924 after the American Society of Mechanical Engineers (ASME) created its first boiler standard in 1884. The American National Standards Institute (ANSI) created the first electric code in 1897. Today, standards set by organizations like API, ASME, and ANSI are viewed as harmonizing standards for the process industries in the United States – also known as Recognized and Generally Accepted Good Engineering Practices (RAGAGEP). These RAGAGEPs form the basis for demonstrating internal compliance with Process Safety Management (PSM) regulations (e.g., OSHA 29 CFR 1910.119, Process Safety Information Section (d)(3)(ii)).

While CFR 1910.119 doesn’t specify what an approved RAGAGEP must contain, it does detail the requirements for operating procedures and training for employees operating a process in Mechanical Integrity sections (j)(2) and (j)(3):

“The employer shall establish and implement written procedures to maintain the ongoing integrity of process equipment. The employer shall train each employee (or contractor) involved in maintaining the on-going integrity of process equipment…and in the procedures applicable to the employee's job tasks.”

This indicates that specialists in the relevant engineering disciplines must receive training in and have a thorough understanding of the standard’s current requirements. This would mean that individuals serving in a RAGAGEP owner role should also be considered as serving in a PSM-critical role.

The purpose of RAGAGEPs is to institute and maintain a chain of custody (i.e., chronological documentation or a paper trail to record the sequence of control, transfer, analysis, and disposition of equipment) for critical equipment involved in handling and controlling hazardous materials, covered by existing PSM regulations. By maintaining this paper trail for all impacted equipment, a piece of equipment’s history can be traced from initial installation to current status – but this is often a tedious, data-intensive process because:

• RAGAGEPs contain a tremendous amount of technical information, and each piece of PSM-critical equipment should have its current RAGAGEP identified along with its maintenance plans and schedules
• Standards are living documents, and, at times, the issuing body edits, replaces, and/or eliminates standards, requiring equipment owners to make periodic adjustments in their maintenance and operations approaches

While paper-based systems can be utilized to maintain RAGAGEP documentation and ensure it is current and up-to-date, this approach has some inherent risks. It often involves a manual process of revising and updating information and limits the accessibility of critical information across an organization.

To more effectively monitor, manage, and maintain RAGAGEP documentation, companies should consider investing in a Computerized Maintenance Management System (CMMS) like OESuite^®. Through the inherent interoperability of OESuite^®, companies can monitor all RAGAGEP documentation, demonstrate internal and external compliance, avoid missing regulatory obligations, and manage resources more effectively – creating one source of truth within a single system interface.

Are you ready to put critical RAGAGEPs information into the hands of the people who need it most in your organization? Connect with an OS expert to learn more.