Complying with OSHA's RNEP, CNEP, and VPP RAGAGEP



The OSHA Refinery National Emphasis Program (RNEP) and OSHA Voluntary Protection Program incorporate specific questions relative to many recognized and generally accepted good engineering practices (RAGAGEP). Many of the same RAGAGEP can be expected to be used in the OSHA Chemicals NEP as well. To comply with OSHA's process safety management (PSM) regulation and improve process safety at their sites, chemical industry personnel should be aware of what RAGAGEP OSHA is recognizing and inspecting against and their key requirements. This article will discuss: (1) OSHA's expectations for compliance with RAGAGEP, including some of the RAGAGEP OSHA references in compliance directives, instructions, and citations, (2) some citations issued by OSHA involving RAGAGEP, and (3) common RAGAGEP compliance issues ABSG Consulting observes when conducting PSM audits and assessments throughout the petrochemical and related industries. © 2011 American Institute of Chemical Engineers Process Saf Prog, 2011