OSHA first introduced the concept of RAGAGEP in their PSM (Process Safety Management) standard, CFR 1910.119. Engineers and operators need to make every effort to follow established engineering practices when designing and maintaining process equipment. However, OSHA does not require RAGAGEP, but leaves this decision to the Owner/Operator. There is no specific definition of what constitutes RAGAGEP. OSHA and the industry have initiated an effort to obtain agreement on the list of RAGAGEP, but as of today, nothing has been finalized.

Further complicating this, many of the standards (e.g., API STD 521) currently published do not provide specific guidance for every situation. Instead, ‘gray areas’ are left in the standards due to the inability to obtain consensus among the members of the API Subcommittees. In many instances, specific guidance from API is not available, 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.

E2G|The Equity Engineering Group, Inc. understands the struggle of determining the appropriate RAGAGEP for your facility. We’ve participated in the API (American Petroleum Institute) 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.

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