RAGAGEP Auditing
Fill in the Gaps
Have you ever struggled through the maze of Codes and Standards related to pressure relief systems and found it difficult to determine what the appropriate RAGAGEP required for your facility is? Equity Engineering has been there and can help. We’ve participated in the API standards writing process since 1990 as part of the Pressure Relieving Subcommittee, and we have performed numerous pressure relief systems design calculations and conducted audits for existing facilities.
OSHA first introduced the concept of Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) in their Process Safety Management (PSM) standard, CFR 1910.119. The concept is that engineers and operators need to make every effort to follow established engineering practices when designing and maintaining process equipment. However, OSHA does not stipulate RAGAGEP, but leaves this up to the Owner/Operator. There is no specific definition of what constitutes RAGAGEP. OSHA and the industry have initiated an effort to get agreement on the list of RAGAGEP, but as of today, nothing has been finalized.
Further complicating this is the fact that many of the standards (e.g. API STD 521) currently published do not provide specific relief system guidance for every situation. Instead, ‘grey areas’ are left in the standards due to the inability to get consensus among the members of the PRS Subcommittee. In many instances, specific guidance from API is not given and the reader cannot always completely define the action necessary for adherence. At that point, the corporate standards are usually written to fill in the gaps. Additionally, AIChE publications from CCPS (Center for Chemical Process Safety) and DIERS (Design Institute for Emergency Relief Systems) are used to supplement the ASME and API publications related to pressure relieving systems.
If you need assistance, please contact our Process Technologies Group and we will be glad to help.
Mr. Henry is responsible for engineering consulting services in the areas of Pressure Relief, Heat Transfer and Fluid Flow. He is a specialist in the design, installation, sizing and selection of pressure relief devices and relieving systems, and is currently chairman of the API Pressure Relieving System Subcommittee’s Task Force on API 520 related to the design and installation of pressure relieving systems. He conducts audits of pressure relieving systems to ensure compliance with OSHA PSM legislation and ASME, API and DIERs Standards, Codes and Publications. He also teaches the official API Pressure Relieving Systems course.
Mr. Buccilli brings a depth of experience covering the full project life-cycle; from business requirements gathering, to design/procurement activities, to construction/commissioning activities, to operations activities, and finally to closeout activities in various types of projects. Mr. Buccilli uses the PMBOK principles and project management analysis tools to solve problems in the most practical, cost-effective manner. 
