
Standard Number:
1910.119
1910.119(a)(1)(i)
1910.119(a)(1)(ii)
1910.119(b)
1910.119(j)(1)
1910.180(d)
1910.269
1910.269(a)(1)
1910.269(a)(1)(iii)
1910.269(p)(1)(i)
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain
these requirements and how they apply to particular circumstances, but they cannot create additional
employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note
that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we
update our guidance in response to new information. To keep apprised of such developments, you can
consult OSHA's website at https://www.osha.gov.
January 31, 2008
Mr. Howard J. Feldman
Director, Regulatory Analysis and Scientific Affairs
American Petroleum Institute
1220 L Street, NW
Washington, DC 20005-4070
Dear Mr. Feldman:
Thank you for your May 12, 2004 letter to the Occupational Safety and Health Administration's
(OSHA's) Directorate of Enforcement Programs (DEP). Our response is based on information you
provided in your letter, and information individuals representing your organization and other
representatives from Synergy presented in a meeting with members of my staff, attorneys from
the Department of Labor Solicitors Office, representatives from the U.S. Environmental
Protection Agency, and me on May 17, 2004 in our building. You have issues regarding
OSHA's Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting
Agents Standard (PSM), 29 CFR 1910.119. Please be aware that this response may not be
applicable to any question or situation not delineated within your original correspondence. Your
specific issues are related to the application of OSHA's requirements for utility systems as they
relate to the prevention and mitigation of releases of highly hazardous chemicals from PSMcovered processes and whether OSHA's standard 29 CFR 1910.269, Electrical Power Generation,
Transmission and Distribution, preempts the PSM standard for power generation facilities that
serve covered processes.
Issue 1 – PSM Coverage of Utility Systems
From your incoming letter, issue paper, and attachments, the following scenario summarizes the
information you have provided in your request to have OSHA clarify guidance that utility systems
are not covered by PSM.
Scenario: Plant utility systems such as steam, nitrogen, electricity, plant air, and process water
are used to operate refinery equipment and processes that may be covered by OSHA's PSM
standard. You stated that API believes that:








the PSM standard does not apply specifically to these utility systems;
the standard industry practice is to consider utilities in the Process Hazard Analysis (PHA)
for covered process;
the language of the PSM standard, the rulemaking record, and other guidance published by
OSHA establish that utilities are not "processes" under the PSM standard;
OSHA has always intended employers to address the impact of a failure of utilities in their
PHAs and not to treat utilities as covered processes;
PSM was developed to address systems management of processes that have the potential
for catastrophic impacts if compromised;
plant utilities, in and of themselves, do not pose this catastrophic potential and do not
contain threshold quantities of hazardous substances. In fact, all of the aforementioned
utilities do not contain any hazardous substances as outlined under PSM;
utilities can have an impact on a covered process; and
adequate safety measures are in place throughout the petroleum industry that cover the
safe operation and maintenance of plant utility equipment and systems. API, CCPS, NFPA,
and other industry and professional societies have developed numerous industry
standards on safe work procedures, equipment integrity, and fire prevention practices that
cover utilities and other equipment and processes that are not in the scope of PSM.
Response 1: Based on the PSM standard, a history of catastrophic incidents involving the failure
of utility systems resulting in the release of hazardous chemicals, and industry practice, we
concur with much of the information you have provided to us regarding utility systems and their
relationship to preventing and mitigating catastrophic releases of highly hazardous chemicals
(HHC) from PSM-covered processes.
Areas of Agreement Related to Utility Systems and Their Relationship to PSM
We agree with you and your representatives on the following points related to utility systems
and their relationship to PSM:
Plant utility systems are used to operate chemical processes which may or may not be
covered by PSM;
 OSHA has always intended employers to address the impact of a failure of utilities in their
PHA;
 If the employer determines that the loss of utilities could result in a potential release of
HHC from the process, then, the employer would determine which engineering controls,
standard operating procedures, instrumentation, employee training, etc. would be
necessary to prevent or minimize the potential loss of a utility from contributing to a
catastrophic release;
 Plant utility systems do not normally contain HHCs;
 Just as there are recognized and generally accepted good engineering practices
(RAGAGEPs) for equipment (e.g., pressure vessels – ASME Boiler and Pressure Vessel Code
and API 510; Piping, Valves and Fittings – API 570; etc.) which contain HHCs and are part
of a PSM-covered process, there are RAGAGEPs for other equipment which may or may not
contain HHCs and may or may not be part of the covered process;
 The boundaries of a PSM-covered process are determined by the PSM standard's
requirements – 1910.119(a)(1)(i)1 and (a)(1)(ii)2 and the definition of process3 found at
1910.119(b).
 The boundaries of the covered process are based on the equipment which contain HHCs,
either through interconnection or separate vessels which are located such that an
explosion would affect interconnected and nearby unconnected vessels which contain
quantities of the HHC that when added together would exceed the threshold quantity and
provide a potential for a catastrophic release.
Failure of a Utility System can be a Pre-condition for a Catastrophic Release

As you mentioned, plant utility systems are used to operate chemical processes. Plant operation,
of course, not only includes production considerations, but also involves safety. In fact, many
parts or aspects of the PSM-covered process are important for preventing and mitigating
catastrophic releases. These parts or aspects include:


those whose failure could lead directly to a catastrophic release (e.g., a flexible hose
connection, pump seals, vessel/tank welds);
those whose failure creates the necessary pre-conditions for a catastrophic release
occurring (e.g., an inerting system, a utility system, a lube oil system on a large
compressor, software for a distributive control system, portable combustible gas meter);
all safety devices, both mechanical and instrumentation (e.g., relief valves and rupture
disk, gas detectors, safety instrumented systems); and
 all means of limiting the potential damage (e.g., emergency equipment – fire prevention
and protection systems, deluge systems, evacuation alarms, etc.).
Utility Systems Are Part of the PSM-covered Process

OSHA does not agree that utility systems are categorically outside the scope and application of
the PSM standard. It is OSHA's long-standing position that utility systems are part of the PSMcovered process when employers use them to control/prevent and mitigate catastrophic releases
of HHC.
A process is defined in 29 CFR 1910.119(b) as any activity involving a highly hazardous chemical
including any use, storage, manufacturing, handling, or the on-site movement of such chemicals,
or a combination of these activities (emphasis added). In the preamble to the final rule, OSHA
noted, specifically, that the standard, as written, reflects the intent of the Clean Air Act
Amendments, which requires the standard to be designed to protect employees from hazards
associated with accidental releases of highly hazardous chemicals in the workplace. 57 FR 6356,
6372 (February 24, 1992). As such, the proper safe functioning of all aspects of a process,
whether they contain HHC or not, are important for the prevention and mitigation of catastrophic
releases of HHC, due to their direct involvement in the overall functioning of the process.
As a result, it is OSHA's position that if an employer determines that a utility system or any aspect
or part of a process which does not contain an HHC but can affect or cause a release of HHC or
interfere in the mitigation of the consequences of a release, then, relevant elements of PSM could
apply to these aspects. OSHA's position is that any engineering control, including utility systems,
which meets the above criteria must be, at a minimum, evaluated, designed, installed, operated
(training and procedures), changed, and inspected/tested/maintained4 per OSHA PSM
requirements.
If an employer determines, through a PHA, that a component failure of a utility system can no
longer affect or cause a release of HHC or interfere in the mitigation of the consequences of the
release, then, the utility system, at that point, would no longer be considered part of the covered
process. If an employer makes this determination, then, the employer must be able to proactively
demonstrate why the utility system is no longer part of the covered process.
If the employer takes credit for other credible safeguards in the process, which will prevent and
mitigate a release of an HHC in lieu of the subject utility system, then, they must assure that those
safeguards are adequate. For example, an employer determines, through its PHA, that its
electrical utility system needs to be relied upon for the safe operation of their covered process. In
response, the employer determines that an uninterruptible power supply (UPS) would be a
safeguard against the loss of electrical utility to the process equipment. With respect to this
example, one scenario the employer would need to account for would be the need to assure that
the on-site electrical distribution system, from the main power supply and the UPS, would not be
compromised by an explosion or some other reason. In this case, if the electrical utility cannot
function to safely operate the process because the electrical distribution system is compromised,
the UPS safeguard would not be a credible safeguard for the process. Again, for aspects which do
not contain HHCs, OSHA expects those other credited safeguards would, at a minimum, be
evaluated, designed, installed, operated (training and procedures), changed, and
inspected/tested/maintained per OSHA PSM requirements.
In your incoming document package, you asked us to withdraw an interpretation letter 5 on the
matter of PSM coverage of utilities. We are not withdrawing this interpretation letter because we
believe it accurately reflects our long-standing enforcement policy as discussed above. To
reiterate, OSHA's position regarding PSM coverage of utility systems is as follows: Based on the
employer's analysis, utility systems may be subject to various elements of PSM to the point where
a failure in a component of the utility system can no longer affect a potential release of a covered
chemical. It is OSHA's view that utility systems that are part of the covered process need to be, at
a minimum, depending on the circumstances of the process in question, evaluated, designed,
installed, operated (training and procedures), changed, and inspected/tested/maintained per
OSHA PSM requirements.
Issue 2 – Preemption of the PSM Standard by OSHA's 1910.269 Standard
Scenario: Based on API's analysis, you believe that OSHA's 1910.269 standard, Electric Power
Generation, Transmission, and Distribution, preempts the application of the PSM standard to
electrical utility systems at facilities with PSM-covered processes. The bases of your preemption
conclusion are that:
this standard, as stated in 1910.269(a)(1), applies to "the operation and maintenance of
electric power generation, control, transformation, transmission, and distribution lines
and equipment" and is the vertical standard governing the electric utility industry;
 a vertical standard generally preempts a horizontal standard, provided that the vertical
standard contains provisions addressing the safety issues covered by the horizontal
standard;
 1910.269 covers electrical generating stations owned and operated by facilities with PSMcovered processes, as well as electric utilities that provide power to customers; and
 1910.269 regulates the same industrial power generation that OSHA implies is regulated
by the PSM standard. 1910.269 regulates the same hazards addressed by the PSM
standard by requiring measures such as safety procedures and operator training. As the
vertical standard applicable to electric power generation, 1910.269, therefore, preempts
the application of the PSM standard to on-site power generating facilities that serve
covered processes.
Response 2: The 1910.269 standard does apply to the operation and maintenance of electric
power generation, control, transformation, transmission, and distribution lines and equipment.
However, as the regulatory text and the preamble provide, OSHA did not intend for the 1910.269
standard to preempt the application of the PSM standard at covered processes/facilities. OSHA
explicitly stated in 1910.269(a)(1)(iii) (emphasis added):

This section applies in addition to all other applicable standards contained in this Part 1910.
Specific references in this section to other sections of Part 1910 are provided for emphasis only.
Further, OSHA explained in the preamble to the 1910.269 standard that other Part 1910
standards (e.g., 1910.119 – PSM) are not preempted by 1910.269, unless an exception is given in
1910.269:
Paragraph (a)(1)(iii) of final 1910.269 explains the application of the section with respect to
thev rest of part 1910. All other General Industry Standards continue to apply to installations
covered by this new standard unless an exception is given in 1910.269. For example,
1910.269(p)(1)(i) requires the critical components of mechanical elevating and rotating
equipment to be inspected before each shift. This provision does not supersede existing
1910.180(d), which details specific requirements for the inspection of cranes. References in
1910.269 to other sections of part 1910 are provided only for emphasis.
59 FR 4320, 4341 (Jan. 31, 1994)
As you stated, the application of the 1910.269 standard is for the operation and maintenance of
electric power generation, control, transformation, transmission, and distribution lines and
equipment. The purpose and application of the PSM standard is to prevent and mitigate
catastrophic releases of HHC, which include fire/explosion hazards, toxic hazards, reactive
hazards, and explosive hazards. As stated in Response 1, utility systems, including electrical
utility systems can be part of a covered process. As such, they are one component part of a
holistic safety system for a PSM-covered process and relevant provisions of both 1910.119 and
1910.269 are applicable. Indeed, this result is necessary to protect employee safety. The
application of 1910.269 procedures alone would not adequately prevent and mitigate the release
of HHCs and their associated hazards – fire/explosion due to the release of flammable materials
and toxic, reactive, and explosive material hazards – that are subject to PSM provisions.
Additionally, 1910.269 does not address the hazards associated with PSM-covered processes in a
holistic manner, as is required by the management systems elements of the PSM standard.
Therefore, given OSHA's intent, as explicitly stated in the 1910.269 standard and preamble, and
the differing hazards and requirements to assure safe operations, the 1910.269 standard does
not preempt application of the PSM standard.
Thank you for your interest in occupational safety and health. We hope you find this information
helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation
letters explain these requirements and how they apply to particular circumstances, but they
cannot create additional employer obligations. This letter constitutes OSHA's interpretation of
the requirements discussed. Note that our enforcement guidance may be affected by changes to
OSHA rules. Also, from time to time we update our guidance in response to new information. To
keep apprised of such developments, you may consult OSHA's website at http://www.osha.gov If
you have any further questions, please feel free to contact the OSHA Office of General Industry
Enforcement at (202) 693-1850.
Sincerely,
Richard E. Fairfax, Director
Directorate of Enforcement Programs
1910.119(a)(1)(i) – This section applies to the following – A process which involves a chemical
at or above the specified threshold quantities listed in Appendix A to this section; [ back to text ]
1
2
1910.119(a)(1)(ii) – A process which involves a flammable liquid or gas (as defined in
1910.1200(c) of this part) on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or
more. . . [ back to text ]
1910.119(b) – "Process" means any activity involving a highly hazardous chemical including
any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or
combination of these activities. For purposes of this definition, any group of vessels which are
interconnected and separate vessels which are located such that a highly hazardous chemical
could be involved in a potential release shall be considered a single process. [ back to text ]
3
OSHA stated in the PSM preamble [FR Vol. 57, No. 36, pg. 6389] that other equipment (i.e.,
aspects), than that equipment identified in 1910.119(j)(1) might be critical to the safety of the
process, It is the position of OSHA that at least the equipment specified in proposed paragraph
4
(j)(1) must be subject to the requirements contained in paragraph (j). However, if an employer
deems additional equipment to be critical to a particular process, that employer should consider
that equipment to be covered by this paragraph and treat it accordingly. [ back to text ]
OSHA Interpretation Letter to James B. Evans, Union Carbide, The term "interconnection" as it
would apply to utilities, steam and electric, used in a covered process. 9/14/95,
[http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_
id=21932] [ back to text ]
5

Part Number:
1910

Part Number Title:
Occupational Safety and Health Standards

Subpart:
1910 Subpart H

Subpart Title:
Hazardous Materials

Standard Number:
1910.119

Title:
Process safety management of highly hazardous chemicals.

Appendix:
A
B
C
D

GPO Source:
e-CFR
Purpose. This section contains requirements for preventing or minimizing the consequences of
catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may
result in toxic, fire or explosion hazards.
1910.119(a)
Application.
1910.119(a)(1)
This section applies to the following:
1910.119(a)(1)(i)
A process which involves a chemical at or above the specified threshold quantities listed in
appendix A to this section;
1910.119(a)(1)(ii)
A process which involves a Category 1 flammable gas (as defined in 1910.1200(c)) or a
flammable liquid with a flashpoint below 100 °F (37.8 °C) on site in one location, in a quantity of
10,000 pounds (4535.9 kg) or more except for:
1910.119(a)(1)(ii)(A)
Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for
comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing
another highly hazardous chemical covered by this standard;
1910.119(a)(1)(ii)(B)
Flammable liquids with a flashpoint below 100 °F (37.8 °C) stored in atmospheric tanks or
transferred which are kept below their normal boiling point without benefit of chilling or
refrigeration.
1910.119(a)(2)
This section does not apply to:
1910.119(a)(2)(i)
Retail facilities;
1910.119(a)(2)(ii)
Oil or gas well drilling or servicing operations; or,
1910.119(a)(2)(iii)
Normally unoccupied remote facilities.
1910.119(b)
Definitions. Atmospheric tank means a storage tank which has been designed to operate at
pressures from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge, 3.45 Kpa).
Boiling point means the boiling point of a liquid at a pressure of 14.7 pounds per square inch
absolute (p.s.i.a.) (760 mm.). For the purposes of this section, where an accurate boiling point is
unavailable for the material in question, or for mixtures which do not have a constant boiling
point, the 10 percent point of a distillation performed in accordance with the Standard Method of
Test for Distillation of Petroleum Products, ASTM D-86-62, which is incorporated by reference as
specified in §1910.6, may be used as the boiling point of the liquid.
Catastrophic release means a major uncontrolled emission, fire, or explosion, involving one or
more highly hazardous chemicals, that presents serious danger to employees in the workplace.
Facility means the buildings, containers or equipment which contain a process.
Highly hazardous chemical means a substance possessing toxic, reactive, flammable, or explosive
properties and specified by paragraph (a)(1) of this section.
Hot work means work involving electric or gas welding, cutting, brazing, or similar flame or
spark-producing operations.
Normally unoccupied remote facility means a facility which is operated, maintained or serviced
by employees who visit the facility only periodically to check its operation and to perform
necessary operating or maintenance tasks. No employees are permanently stationed at the
facility.
Facilities meeting this definition are not contiguous with, and must be geographically remote
from all other buildings, processes or persons.
Process means any activity involving a highly hazardous chemical including any use, storage,
manufacturing, handling, or the on-site movement of such chemicals, or combination of these
activities. For purposes of this definition, any group of vessels which are interconnected and
separate vessels which are located such that a highly hazardous chemical could be involved in a
potential release shall be considered a single process.
Replacement in kind means a replacement which satisfies the design specification.
Trade secret means any confidential formula, pattern, process, device, information or
compilation of information that is used in an employer's business, and that gives the employer an
opportunity to obtain an advantage over competitors who do not know or use it. See Appendix E
to §1910.1200 — Definition of a Trade Secret (which sets out the criteria to be used in evaluating
trade secrets).
1910.119(c)
Employee participation.
1910.119(c)(1)
Employers shall develop a written plan of action regarding the implementation of the employee
participation required by this paragraph.
1910.119(c)(2)
Employers shall consult with employees and their representatives on the conduct and
development of process hazards analyses and on the development of the other elements of
process safety management in this standard.
1910.119(c)(3)
Employers shall provide to employees and their representatives access to process hazard
analyses and to all other information required to be developed under this standard.
1910.119(d)
Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this
section, the employer shall complete a compilation of written process safety information before
conducting any process hazard analysis required by the standard. The compilation of written
process safety information is to enable the employer and the employees involved in operating the
process to identify and understand the hazards posed by those processes involving highly
hazardous chemicals. This process safety information shall include information pertaining to the
hazards of the highly hazardous chemicals used or produced by the process, information
pertaining to the technology of the process, and information pertaining to the equipment in the
process.
1910.119(d)(1)
Information pertaining to the hazards of the highly hazardous chemicals in the process. This
information shall consist of at least the following:
1910.119(d)(1)(i)
Toxicity information;
1910.119(d)(1)(ii)
Permissible exposure limits;
1910.119(d)(1)(iii)
Physical data;
1910.119(d)(1)(iv)
Reactivity data:
1910.119(d)(1)(v)
Corrosivity data;
1910.119(d)(1)(vi)
Thermal and chemical stability data; and
1910.119(d)(1)(vii)
Hazardous effects of inadvertent mixing of different materials that could foreseeably occur.
Note:
Safety data sheets meeting the requirements of 29 CFR 1910.1200(g) may be used to comply
with this requirement to the extent they contain the information required by this subparagraph.
1910.119(d)(2)
Information pertaining to the technology of the process.
1910.119(d)(2)(i)
Information concerning the technology of the process shall include at least the following:
1910.119(d)(2)(i)(A)
A block flow diagram or simplified process flow diagram (see appendix B to this section);
1910.119(d)(2)(i)(B)
Process chemistry;
1910.119(d)(2)(i)(C)
Maximum intended inventory;
1910.119(d)(2)(i)(D)
Safe upper and lower limits for such items as temperatures, pressures, flows or compositions;
and,
1910.119(d)(2)(i)(E)
An evaluation of the consequences of deviations, including those affecting the safety and health of
employees.
1910.119(d)(2)(ii)
Where the original technical information no longer exists, such information may be developed in
conjunction with the process hazard analysis in sufficient detail to support the analysis.
1910.119(d)(3)
Information pertaining to the equipment in the process.
1910.119(d)(3)(i)
Information pertaining to the equipment in the process shall include:
1910.119(d)(3)(i)(A)
Materials of construction;
1910.119(d)(3)(i)(B)
Piping and instrument diagrams (P&ID's);
1910.119(d)(3)(i)(C)
Electrical classification;
1910.119(d)(3)(i)(D)
Relief system design and design basis;
1910.119(d)(3)(i)(E)
Ventilation system design;
1910.119(d)(3)(i)(F)
Design codes and standards employed;
1910.119(d)(3)(i)(G)
Material and energy balances for processes built after May 26, 1992; and,
1910.119(d)(3)(i)(H)
Safety systems (e.g. interlocks, detection or suppression systems).
1910.119(d)(3)(ii)
The employer shall document that equipment complies with recognized and generally accepted
good engineering practices.
1910.119(d)(3)(iii)
For existing equipment designed and constructed in accordance with codes, standards, or
practices that are no longer in general use, the employer shall determine and document that the
equipment is designed, maintained, inspected, tested, and operating in a safe manner.
1910.119(e)
Process hazard analysis.
1910.119(e)(1)
The employer shall perform an initial process hazard analysis (hazard evaluation) on processes
covered by this standard. The process hazard analysis shall be appropriate to the complexity of
the process and shall identify, evaluate, and control the hazards involved in the process.
Employers shall determine and document the priority order for conducting process hazard
analyses based on a rationale which includes such considerations as extent of the process
hazards, number of potentially affected employees, age of the process, and operating history of
the process. The process hazard analysis shall be conducted as soon as possible, but not later
than the following schedule:
1910.119(e)(1)(i)
No less than 25 percent of the initial process hazards analyses shall be completed by May 26,
1994;
1910.119(e)(1)(ii)
No less than 50 percent of the initial process hazards analyses shall be completed by May 26,
1995;
1910.119(e)(1)(iii)
No less than 75 percent of the initial process hazards analyses shall be completed by May 26,
1996;
1910.119(e)(1)(iv)
All initial process hazards analyses shall be completed by May 26, 1997.
1910.119(e)(1)(v)
Process hazards analyses completed after May 26, 1987 which meet the requirements of this
paragraph are acceptable as initial process hazards analyses. These process hazard analyses shall
be updated and revalidated, based on their completion date, in accordance with paragraph (e)(6)
of this in accordance with paragraph (e)(6) of this section.
1910.119(e)(2)
The employer shall use one or more of the following methodologies that are appropriate to
determine and evaluate the hazards of the process being analyzed.
1910.119(e)(2)(i)
What-If;
1910.119(e)(2)(ii)
Checklist;
1910.119(e)(2)(iii)
What-If/Checklist;
1910.119(e)(2)(iv)
Hazard and Operability Study (HAZOP):
1910.119(e)(2)(v)
Failure Mode and Effects Analysis (FMEA);
1910.119(e)(2)(vi)
Fault Tree Analysis; or
1910.119(e)(2)(vii)
An appropriate equivalent methodology.
1910.119(e)(3)
The process hazard analysis shall address:
1910.119(e)(3)(i)
The hazards of the process;
1910.119(e)(3)(ii)
The identification of any previous incident which had a likely potential for catastrophic
consequences in the workplace;
1910.119(e)(3)(iii)
Engineering and administrative controls applicable to the hazards and their interrelationships
such as appropriate application of detection methodologies to provide early warning of releases.
(Acceptable detection methods might include process monitoring and control instrumentation
with alarms, and detection hardware such as hydrocarbon sensors.);
1910.119(e)(3)(iv)
Consequences of failure of engineering and administrative controls;
1910.119(e)(3)(v)
Facility siting;
1910.119(e)(3)(vi)
Human factors; and
1910.119(e)(3)(vii)
A qualitative evaluation of a range of the possible safety and health effects of failure of controls
on employees in the workplace.
1910.119(e)(4)
The process hazard analysis shall be performed by a team with expertise in engineering and
process operations, and the team shall include at least one employee who has experience and
knowledge specific to the process being evaluated. Also, one member of the team must be
knowledgeable in the specific process hazard analysis methodology being used.
1910.119(e)(5)
The employer shall establish a system to promptly address the team's findings and
recommendations; assure that the recommendations are resolved in a timely manner and that
the resolution is documented; document what actions are to be taken; complete actions as soon
as possible; develop a written schedule of when these actions are to be completed; communicate
the actions to operating, maintenance and other employees whose work assignments are in the
process and who may be affected by the recommendations or actions.
1910.119(e)(6)
At least every five (5) years after the completion of the initial process hazard analysis, the
process hazard analysis shall be updated and revalidated by a team meeting the requirements in
paragraph (e)(4) of this section, to assure that the process hazard analysis is consistent with the
current process.
1910.119(e)(7)
Employers shall retain process hazards analyses and updates or revalidations for each process
covered by this section, as well as the documented resolution of recommendations described in
paragraph (e)(5) of this section for the life of the process.
1910.119(f)
Operating procedures.
1910.119(f)(1)
The employer shall develop and implement written operating procedures that provide clear
instructions for safely conducting activities involved in each covered process consistent with the
process safety information and shall address at least the following elements.
1910.119(f)(1)(i)
Steps for each operating phase:
1910.119(f)(1)(i)(A)
Initial startup;
1910.119(f)(1)(i)(B)
Normal operations;
1910.119(f)(1)(i)(C)
Temporary operations;
1910.119(f)(1)(i)(D)
Emergency shutdown including the conditions under which emergency shutdown is required,
and the assignment of shutdown responsibility to qualified operators to ensure that emergency
shutdown is executed in a safe and timely manner.
1910.119(f)(1)(i)(E)
Emergency Operations;
1910.119(f)(1)(i)(F)
Normal shutdown; and,
1910.119(f)(1)(i)(G)
Startup following a turnaround, or after an emergency shutdown.
1910.119(f)(1)(ii)
Operating limits:
1910.119(f)(1)(ii)(A)
Consequences of deviation; and
1910.119(f)(1)(ii)(B)
Steps required to correct or avoid deviation.
1910.119(f)(1)(iii)
Safety and health considerations:
1910.119(f)(1)(iii)(A)
Properties of, and hazards presented by, the chemicals used in the process;
1910.119(f)(1)(iii)(B)
Precautions necessary to prevent exposure, including engineering controls, administrative
controls, and personal protective equipment;
1910.119(f)(1)(iii)(C)
Control measures to be taken if physical contact or airborne exposure occurs;
1910.119(f)(1)(iii)(D)
Quality control for raw materials and control of hazardous chemical inventory levels; and,
1910.119(f)(1)(iii)(E)
Any special or unique hazards.
1910.119(f)(1)(iv)
Safety systems and their functions.
1910.119(f)(2)
Operating procedures shall be readily accessible to employees who work in or maintain a
process.
1910.119(f)(3)
The operating procedures shall be reviewed as often as necessary to assure that they reflect
current operating practice, including changes that result from changes in process chemicals,
technology, and equipment, and changes to facilities. The employer shall certify annually that
these operating procedures are current and accurate.
1910.119(f)(4)
The employer shall develop and implement safe work practices to provide for the control of
hazards during operations such as lockout/tagout; confined space entry; opening process
equipment or piping; and control over entrance into a facility by maintenance, contractor,
laboratory, or other support personnel. These safe work practices shall apply to employees and
contractor employees.
1910.119(g)
Training —
1910.119(g)(1)
Initial training.
1910.119(g)(1)(i)
Each employee presently involved in operating a process, and each employee before being
involved in operating a newly assigned process, shall be trained in an overview of the process
and in the operating procedures as specified in paragraph (f) of this section. The training shall
include emphasis on the specific safety and health hazards, emergency operations including
shutdown, and safe work practices applicable to the employee's job tasks.
1910.119(g)(1)(ii)
In lieu of initial training for those employees already involved in operating a process on May 26,
1992, an employer may certify in writing that the employee has the required knowledge, skills,
and abilities to safely carry out the duties and responsibilities as specified in the operating
procedures.
1910.119(g)(2)
Refresher training. Refresher training shall be provided at least every three years, and more
often if necessary, to each employee involved in operating a process to assure that the employee
understands and adheres to the current operating procedures of the process. The employer, in
consultation with the employees involved in operating the process, shall determine the
appropriate frequency of refresher training.
1910.119(g)(3)
Training documentation. The employer shall ascertain that each employee involved in operating
a process has received and understood the training required by this paragraph. The employer
shall prepare a record which contains the identity of the employee, the date of training, and the
means used to verify that the employee understood the training.
1910.119(h)
Contractors 1910.119(h)(1)
Application. This paragraph applies to contractors performing maintenance or repair,
turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not
apply to contractors providing incidental services which do not influence process safety, such as
janitorial work, food and drink services, laundry, delivery or other supply services.
1910.119(h)(2)
Employer responsibilities.
1910.119(h)(2)(i)
The employer, when selecting a contractor, shall obtain and evaluate information regarding the
contract employer's safety performance and programs.
1910.119(h)(2)(ii)
The employer shall inform contract employers of the known potential fire, explosion, or toxic
release hazards related to the contractor's work and the process.
1910.119(h)(2)(iii)
The employer shall explain to contract employers the applicable provisions of the emergency
action plan required by paragraph (n) of this section.
1910.119(h)(2)(iv)
The employer shall develop and implement safe work practices consistent with paragraph (f)(4)
of this section, to control the entrance, presence and exit of contract employers and contract
employees in covered process areas.
1910.119(h)(2)(v)
The employer shall periodically evaluate the performance of contract employers in fulfilling their
obligations as specified in paragraph (h)(3) of this section.
1910.119(h)(2)(vi)
The employer shall maintain a contract employee injury and illness log related to the contractor's
work in process areas.
1910.119(h)(3)
Contract employer responsibilities.
1910.119(h)(3)(i)
The contract employer shall assure that each contract employee is trained in the work practices
necessary to safely perform his/her job.
1910.119(h)(3)(ii)
The contract employer shall assure that each contract employee is instructed in the known
potential fire, explosion, or toxic release hazards related to his/her job and the process, and the
applicable provisions of the emergency action plan.
1910.119(h)(3)(iii)
The contract employer shall document that each contract employee has received and understood
the training required by this paragraph. The contract employer shall prepare a record which
contains the identity of the contract employee, the date of training, and the means used to verify
that the employee understood the training.
1910.119(h)(3)(iv)
The contract employer shall assure that each contract employee follows the safety rules of the
facility including the safe work practices required by paragraph (f)(4) of this section.
1910.119(h)(3)(v)
The contract employer shall advise the employer of any unique hazards presented by the
contract employer's work, or of any hazards found by the contract employer's work.
1910.119(i)
Pre-startup safety review.
1910.119(i)(1)
The employer shall perform a pre-startup safety review for new facilities and for modified
facilities when the modification is significant enough to require a change in the process safety
information.
1910.119(i)(2)
The pre-startup safety review shall confirm that prior to the introduction of highly hazardous
chemicals to a process:
1910.119(i)(2)(i)
Construction and equipment is in accordance with design specifications;
1910.119(i)(2)(ii)
Safety, operating, maintenance, and emergency procedures are in place and are adequate;
1910.119(i)(2)(iii)
For new facilities, a process hazard analysis has been performed and recommendations have
been resolved or implemented before startup; and modified facilities meet the requirements
contained in management of change, paragraph (l).
1910.119(i)(2)(iv)
Training of each employee involved in operating a process has been completed.
1910.119(j)
Mechanical integrity —
1910.119(j)(1)
Application. Paragraphs (j)(2) through (j)(6) of this section apply to the following process
equipment:
1910.119(j)(1)(i)
Pressure vessels and storage tanks;
1910.119(j)(1)(ii)
Piping systems (including piping components such as valves);
1910.119(j)(1)(iii)
Relief and vent systems and devices;
1910.119(j)(1)(iv)
Emergency shutdown systems;
1910.119(j)(1)(v)
Controls (including monitoring devices and sensors, alarms, and interlocks) and,
1910.119(j)(1)(vi)
Pumps.
1910.119(j)(2)
Written procedures. The employer shall establish and implement written procedures to maintain
the on-going integrity of process equipment.
1910.119(j)(3)
Training for process maintenance activities. The employer shall train each employee involved in
maintaining the on-going integrity of process equipment in an overview of that process and its
hazards and in the procedures applicable to the employee's job tasks to assure that the employee
can perform the job tasks in a safe manner.
1910.119(j)(4)
Inspection and testing.
1910.119(j)(4)(i)
Inspections and tests shall be performed on process equipment.
1910.119(j)(4)(ii)
Inspection and testing procedures shall follow recognized and generally accepted good
engineering practices.
1910.119(j)(4)(iii)
The frequency of inspections and tests of process equipment shall be consistent with applicable
manufacturers' recommendations and good engineering practices, and more frequently if
determined to be necessary by prior operating experience.
1910.119(j)(4)(iv)
The employer shall document each inspection and test that has been performed on process
equipment. The documentation shall identify the date of the inspection or test, the name of the
person who performed the inspection or test, the serial number or other identifier of the
equipment on which the inspection or test was performed, a description of the inspection or test
performed, and the results of the inspection or test.
1910.119(j)(5)
Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside
acceptable limits (defined by the process safety information in paragraph (d) of this section)
before further use or in a safe and timely manner when necessary means are taken to assure safe
operation.
1910.119(j)(6)
Quality assurance.
1910.119(j)(6)(i)
In the construction of new plants and equipment, the employer shall assure that equipment as it
is fabricated is suitable for the process application for which they will be used.
1910.119(j)(6)(ii)
Appropriate checks and inspections shall be performed to assure that equipment is installed
properly and consistent with design specifications and the manufacturer's instructions.
1910.119(j)(6)(iii)
The employer shall assure that maintenance materials, spare parts and equipment are suitable
for the process application for which they will be used.
1910.119(k)
Hot work permit.
1910.119(k)(1)
The employer shall issue a hot work permit for hot work operations conducted on or near a
covered process.
1910.119(k)(2)
The permit shall document that the fire prevention and protection requirements in 29 CFR
1910.252(a) have been implemented prior to beginning the hot work operations; it shall indicate
the date(s) authorized for hot work; and identify the object on which hot work is to be
performed. The permit shall be kept on file until completion of the hot work operations.
1910.119(l)
Management of change.
1910.119(l)(1)
The employer shall establish and implement written procedures to manage changes (except for
"replacements in kind") to process chemicals, technology, equipment, and procedures; and,
changes to facilities that affect a covered process.
1910.119(l)(2)
The procedures shall assure that the following considerations are addressed prior to any change:
1910.119(l)(2)(i)
The technical basis for the proposed change;
1910.119(l)(2)(ii)
Impact of change on safety and health;
1910.119(l)(2)(iii)
Modifications to operating procedures;
1910.119(l)(2)(iv)
Necessary time period for the change; and,
1910.119(l)(2)(v)
Authorization requirements for the proposed change.
1910.119(l)(3)
Employees involved in operating a process and maintenance and contract employees whose job
tasks will be affected by a change in the process shall be informed of, and trained in, the change
prior to start-up of the process or affected part of the process.
1910.119(l)(4)
If a change covered by this paragraph results in a change in the process safety information
required by paragraph (d) of this section, such information shall be updated accordingly.
1910.119(l)(5)
If a change covered by this paragraph results in a change in the operating procedures or practices
required by paragraph (f) of this section, such procedures or practices shall be updated
accordingly.
1910.119(m)
Incident investigation.
1910.119(m)(1)
The employer shall investigate each incident which resulted in, or could reasonably have resulted
in a catastrophic release of highly hazardous chemical in the workplace.
1910.119(m)(2)
An incident investigation shall be initiated as promptly as possible, but not later than 48 hours
following the incident.
1910.119(m)(3)
An incident investigation team shall be established and consist of at least one person
knowledgeable in the process involved, including a contract employee if the incident involved
work of the contractor, and other persons with appropriate knowledge and experience to
thoroughly investigate and analyze the incident.
1910.119(m)(4)
A report shall be prepared at the conclusion of the investigation which includes at a minimum:
1910.119(m)(4)(i)
Date of incident;
1910.119(m)(4)(ii)
Date investigation began;
1910.119(m)(4)(iii)
A description of the incident;
1910.119(m)(4)(iv)
The factors that contributed to the incident; and,
1910.119(m)(4)(v)
Any recommendations resulting from the investigation.
1910.119(m)(5)
The employer shall establish a system to promptly address and resolve the incident report
findings and recommendations. Resolutions and corrective actions shall be documented.
1910.119(m)(6)
The report shall be reviewed with all affected personnel whose job tasks are relevant to the
incident findings including contract employees where applicable.
1910.119(m)(7)
Incident investigation reports shall be retained for five years.
1910.119(n)
Emergency planning and response. The employer shall establish and implement an emergency
action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition,
the emergency action plan shall include procedures for handling small releases. Employers
covered under this standard may also be subject to the hazardous waste and emergency
response provisions contained in 29 CFR 1910.120 (a), (p) and (q).
1910.119(o)
Compliance Audits.
1910.119(o)(1)
Employers shall certify that they have evaluated compliance with the provisions of this section at
least every three years to verify that the procedures and practices developed under the standard
are adequate and are being followed.
1910.119(o)(2)
The compliance audit shall be conducted by at least one person knowledgeable in the process.
1910.119(o)(3)
A report of the findings of the audit shall be developed.
1910.119(o)(4)
The employer shall promptly determine and document an appropriate response to each of the
findings of the compliance audit, and document that deficiencies have been corrected.
1910.119(o)(5)
Employers shall retain the two (2) most recent compliance audit reports.
1910.119(p)
Trade secrets.
1910.119(p)(1)
Employers shall make all information necessary to comply with the section available to those
persons responsible for compiling the process safety information (required by paragraph (d) of
this section), those assisting in the development of the process hazard analysis (required by
paragraph (e) of this section), those responsible for developing the operating procedures
(required by paragraph (f) of this section), and those involved in incident investigations
(required by paragraph (m) of this section), emergency planning and response (paragraph (n) of
this section) and compliance audits (paragraph (o) of this section) without regard to possible
trade secret status of such information.
1910.119(p)(2)
Nothing in this paragraph shall preclude the employer from requiring the persons to whom the
information is made available under paragraph (p)(1) of this section to enter into confidentiality
agreements not to disclose the information as set forth in 29 CFR 1910.1200.
1910.119(p)(3)
Subject to the rules and procedures set forth in 29 CFR 1910.1200(i)(1) through
1910.1200(i)(12), employees and their designated representatives shall have access to trade
secret information contained within the process hazard analysis and other documents required
to be developed by this standard.
[57 FR 23060, June 1, 1992; 61 FR 9227, March 7, 1996; 77 FR 17776, March 26, 2012; 78 FR
9313, Feb. 8, 2013]

Part Number:
1910

Part Number Title:
Occupational Safety and Health Standards

Subpart:
1910 Subpart H

Subpart Title:
Hazardous Materials

Standard Number:
1910.119

Title:
Process safety management of highly hazardous chemicals.

Appendix:
A
B
C
D

GPO Source:
e-CFR
Purpose. This section contains requirements for preventing or minimizing the consequences of
catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may
result in toxic, fire or explosion hazards.
1910.119(a)
Application.
1910.119(a)(1)
This section applies to the following:
1910.119(a)(1)(i)
A process which involves a chemical at or above the specified threshold quantities listed in
appendix A to this section;
1910.119(a)(1)(ii)
A process which involves a Category 1 flammable gas (as defined in 1910.1200(c)) or a
flammable liquid with a flashpoint below 100 °F (37.8 °C) on site in one location, in a quantity of
10,000 pounds (4535.9 kg) or more except for:
1910.119(a)(1)(ii)(A)
Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for
comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing
another highly hazardous chemical covered by this standard;
1910.119(a)(1)(ii)(B)
Flammable liquids with a flashpoint below 100 °F (37.8 °C) stored in atmospheric tanks or
transferred which are kept below their normal boiling point without benefit of chilling or
refrigeration.
1910.119(a)(2)
This section does not apply to:
1910.119(a)(2)(i)
Retail facilities;
1910.119(a)(2)(ii)
Oil or gas well drilling or servicing operations; or,
1910.119(a)(2)(iii)
Normally unoccupied remote facilities.
1910.119(b)
Definitions. Atmospheric tank means a storage tank which has been designed to operate at
pressures from atmospheric through 0.5 p.s.i.g. (pounds per square inch gauge, 3.45 Kpa).
Boiling point means the boiling point of a liquid at a pressure of 14.7 pounds per square inch
absolute (p.s.i.a.) (760 mm.). For the purposes of this section, where an accurate boiling point is
unavailable for the material in question, or for mixtures which do not have a constant boiling
point, the 10 percent point of a distillation performed in accordance with the Standard Method of
Test for Distillation of Petroleum Products, ASTM D-86-62, which is incorporated by reference as
specified in §1910.6, may be used as the boiling point of the liquid.
Catastrophic release means a major uncontrolled emission, fire, or explosion, involving one or
more highly hazardous chemicals, that presents serious danger to employees in the workplace.
Facility means the buildings, containers or equipment which contain a process.
Highly hazardous chemical means a substance possessing toxic, reactive, flammable, or explosive
properties and specified by paragraph (a)(1) of this section.
Hot work means work involving electric or gas welding, cutting, brazing, or similar flame or
spark-producing operations.
Normally unoccupied remote facility means a facility which is operated, maintained or serviced
by employees who visit the facility only periodically to check its operation and to perform
necessary operating or maintenance tasks. No employees are permanently stationed at the
facility.
Facilities meeting this definition are not contiguous with, and must be geographically remote
from all other buildings, processes or persons.
Process means any activity involving a highly hazardous chemical including any use, storage,
manufacturing, handling, or the on-site movement of such chemicals, or combination of these
activities. For purposes of this definition, any group of vessels which are interconnected and
separate vessels which are located such that a highly hazardous chemical could be involved in a
potential release shall be considered a single process.
Replacement in kind means a replacement which satisfies the design specification.
Trade secret means any confidential formula, pattern, process, device, information or
compilation of information that is used in an employer's business, and that gives the employer an
opportunity to obtain an advantage over competitors who do not know or use it. See Appendix E
to §1910.1200 — Definition of a Trade Secret (which sets out the criteria to be used in evaluating
trade secrets).
1910.119(c)
Employee participation.
1910.119(c)(1)
Employers shall develop a written plan of action regarding the implementation of the employee
participation required by this paragraph.
1910.119(c)(2)
Employers shall consult with employees and their representatives on the conduct and
development of process hazards analyses and on the development of the other elements of
process safety management in this standard.
1910.119(c)(3)
Employers shall provide to employees and their representatives access to process hazard
analyses and to all other information required to be developed under this standard.
1910.119(d)
Process safety information. In accordance with the schedule set forth in paragraph (e)(1) of this
section, the employer shall complete a compilation of written process safety information before
conducting any process hazard analysis required by the standard. The compilation of written
process safety information is to enable the employer and the employees involved in operating the
process to identify and understand the hazards posed by those processes involving highly
hazardous chemicals. This process safety information shall include information pertaining to the
hazards of the highly hazardous chemicals used or produced by the process, information
pertaining to the technology of the process, and information pertaining to the equipment in the
process.
1910.119(d)(1)
Information pertaining to the hazards of the highly hazardous chemicals in the process. This
information shall consist of at least the following:
1910.119(d)(1)(i)
Toxicity information;
1910.119(d)(1)(ii)
Permissible exposure limits;
1910.119(d)(1)(iii)
Physical data;
1910.119(d)(1)(iv)
Reactivity data:
1910.119(d)(1)(v)
Corrosivity data;
1910.119(d)(1)(vi)
Thermal and chemical stability data; and
1910.119(d)(1)(vii)
Hazardous effects of inadvertent mixing of different materials that could foreseeably occur.
Note:
Safety data sheets meeting the requirements of 29 CFR 1910.1200(g) may be used to comply
with this requirement to the extent they contain the information required by this subparagraph.
1910.119(d)(2)
Information pertaining to the technology of the process.
1910.119(d)(2)(i)
Information concerning the technology of the process shall include at least the following:
1910.119(d)(2)(i)(A)
A block flow diagram or simplified process flow diagram (see appendix B to this section);
1910.119(d)(2)(i)(B)
Process chemistry;
1910.119(d)(2)(i)(C)
Maximum intended inventory;
1910.119(d)(2)(i)(D)
Safe upper and lower limits for such items as temperatures, pressures, flows or compositions;
and,
1910.119(d)(2)(i)(E)
An evaluation of the consequences of deviations, including those affecting the safety and health of
employees.
1910.119(d)(2)(ii)
Where the original technical information no longer exists, such information may be developed in
conjunction with the process hazard analysis in sufficient detail to support the analysis.
1910.119(d)(3)
Information pertaining to the equipment in the process.
1910.119(d)(3)(i)
Information pertaining to the equipment in the process shall include:
1910.119(d)(3)(i)(A)
Materials of construction;
1910.119(d)(3)(i)(B)
Piping and instrument diagrams (P&ID's);
1910.119(d)(3)(i)(C)
Electrical classification;
1910.119(d)(3)(i)(D)
Relief system design and design basis;
1910.119(d)(3)(i)(E)
Ventilation system design;
1910.119(d)(3)(i)(F)
Design codes and standards employed;
1910.119(d)(3)(i)(G)
Material and energy balances for processes built after May 26, 1992; and,
1910.119(d)(3)(i)(H)
Safety systems (e.g. interlocks, detection or suppression systems).
1910.119(d)(3)(ii)
The employer shall document that equipment complies with recognized and generally accepted
good engineering practices.
1910.119(d)(3)(iii)
For existing equipment designed and constructed in accordance with codes, standards, or
practices that are no longer in general use, the employer shall determine and document that the
equipment is designed, maintained, inspected, tested, and operating in a safe manner.
1910.119(e)
Process hazard analysis.
1910.119(e)(1)
The employer shall perform an initial process hazard analysis (hazard evaluation) on processes
covered by this standard. The process hazard analysis shall be appropriate to the complexity of
the process and shall identify, evaluate, and control the hazards involved in the process.
Employers shall determine and document the priority order for conducting process hazard
analyses based on a rationale which includes such considerations as extent of the process
hazards, number of potentially affected employees, age of the process, and operating history of
the process. The process hazard analysis shall be conducted as soon as possible, but not later
than the following schedule:
1910.119(e)(1)(i)
No less than 25 percent of the initial process hazards analyses shall be completed by May 26,
1994;
1910.119(e)(1)(ii)
No less than 50 percent of the initial process hazards analyses shall be completed by May 26,
1995;
1910.119(e)(1)(iii)
No less than 75 percent of the initial process hazards analyses shall be completed by May 26,
1996;
1910.119(e)(1)(iv)
All initial process hazards analyses shall be completed by May 26, 1997.
1910.119(e)(1)(v)
Process hazards analyses completed after May 26, 1987 which meet the requirements of this
paragraph are acceptable as initial process hazards analyses. These process hazard analyses shall
be updated and revalidated, based on their completion date, in accordance with paragraph (e)(6)
of this in accordance with paragraph (e)(6) of this section.
1910.119(e)(2)
The employer shall use one or more of the following methodologies that are appropriate to
determine and evaluate the hazards of the process being analyzed.
1910.119(e)(2)(i)
What-If;
1910.119(e)(2)(ii)
Checklist;
1910.119(e)(2)(iii)
What-If/Checklist;
1910.119(e)(2)(iv)
Hazard and Operability Study (HAZOP):
1910.119(e)(2)(v)
Failure Mode and Effects Analysis (FMEA);
1910.119(e)(2)(vi)
Fault Tree Analysis; or
1910.119(e)(2)(vii)
An appropriate equivalent methodology.
1910.119(e)(3)
The process hazard analysis shall address:
1910.119(e)(3)(i)
The hazards of the process;
1910.119(e)(3)(ii)
The identification of any previous incident which had a likely potential for catastrophic
consequences in the workplace;
1910.119(e)(3)(iii)
Engineering and administrative controls applicable to the hazards and their interrelationships
such as appropriate application of detection methodologies to provide early warning of releases.
(Acceptable detection methods might include process monitoring and control instrumentation
with alarms, and detection hardware such as hydrocarbon sensors.);
1910.119(e)(3)(iv)
Consequences of failure of engineering and administrative controls;
1910.119(e)(3)(v)
Facility siting;
1910.119(e)(3)(vi)
Human factors; and
1910.119(e)(3)(vii)
A qualitative evaluation of a range of the possible safety and health effects of failure of controls
on employees in the workplace.
1910.119(e)(4)
The process hazard analysis shall be performed by a team with expertise in engineering and
process operations, and the team shall include at least one employee who has experience and
knowledge specific to the process being evaluated. Also, one member of the team must be
knowledgeable in the specific process hazard analysis methodology being used.
1910.119(e)(5)
The employer shall establish a system to promptly address the team's findings and
recommendations; assure that the recommendations are resolved in a timely manner and that
the resolution is documented; document what actions are to be taken; complete actions as soon
as possible; develop a written schedule of when these actions are to be completed; communicate
the actions to operating, maintenance and other employees whose work assignments are in the
process and who may be affected by the recommendations or actions.
1910.119(e)(6)
At least every five (5) years after the completion of the initial process hazard analysis, the
process hazard analysis shall be updated and revalidated by a team meeting the requirements in
paragraph (e)(4) of this section, to assure that the process hazard analysis is consistent with the
current process.
1910.119(e)(7)
Employers shall retain process hazards analyses and updates or revalidations for each process
covered by this section, as well as the documented resolution of recommendations described in
paragraph (e)(5) of this section for the life of the process.
1910.119(f)
Operating procedures.
1910.119(f)(1)
The employer shall develop and implement written operating procedures that provide clear
instructions for safely conducting activities involved in each covered process consistent with the
process safety information and shall address at least the following elements.
1910.119(f)(1)(i)
Steps for each operating phase:
1910.119(f)(1)(i)(A)
Initial startup;
1910.119(f)(1)(i)(B)
Normal operations;
1910.119(f)(1)(i)(C)
Temporary operations;
1910.119(f)(1)(i)(D)
Emergency shutdown including the conditions under which emergency shutdown is required,
and the assignment of shutdown responsibility to qualified operators to ensure that emergency
shutdown is executed in a safe and timely manner.
1910.119(f)(1)(i)(E)
Emergency Operations;
1910.119(f)(1)(i)(F)
Normal shutdown; and,
1910.119(f)(1)(i)(G)
Startup following a turnaround, or after an emergency shutdown.
1910.119(f)(1)(ii)
Operating limits:
1910.119(f)(1)(ii)(A)
Consequences of deviation; and
1910.119(f)(1)(ii)(B)
Steps required to correct or avoid deviation.
1910.119(f)(1)(iii)
Safety and health considerations:
1910.119(f)(1)(iii)(A)
Properties of, and hazards presented by, the chemicals used in the process;
1910.119(f)(1)(iii)(B)
Precautions necessary to prevent exposure, including engineering controls, administrative
controls, and personal protective equipment;
1910.119(f)(1)(iii)(C)
Control measures to be taken if physical contact or airborne exposure occurs;
1910.119(f)(1)(iii)(D)
Quality control for raw materials and control of hazardous chemical inventory levels; and,
1910.119(f)(1)(iii)(E)
Any special or unique hazards.
1910.119(f)(1)(iv)
Safety systems and their functions.
1910.119(f)(2)
Operating procedures shall be readily accessible to employees who work in or maintain a
process.
1910.119(f)(3)
The operating procedures shall be reviewed as often as necessary to assure that they reflect
current operating practice, including changes that result from changes in process chemicals,
technology, and equipment, and changes to facilities. The employer shall certify annually that
these operating procedures are current and accurate.
1910.119(f)(4)
The employer shall develop and implement safe work practices to provide for the control of
hazards during operations such as lockout/tagout; confined space entry; opening process
equipment or piping; and control over entrance into a facility by maintenance, contractor,
laboratory, or other support personnel. These safe work practices shall apply to employees and
contractor employees.
1910.119(g)
Training —
1910.119(g)(1)
Initial training.
1910.119(g)(1)(i)
Each employee presently involved in operating a process, and each employee before being
involved in operating a newly assigned process, shall be trained in an overview of the process
and in the operating procedures as specified in paragraph (f) of this section. The training shall
include emphasis on the specific safety and health hazards, emergency operations including
shutdown, and safe work practices applicable to the employee's job tasks.
1910.119(g)(1)(ii)
In lieu of initial training for those employees already involved in operating a process on May 26,
1992, an employer may certify in writing that the employee has the required knowledge, skills,
and abilities to safely carry out the duties and responsibilities as specified in the operating
procedures.
1910.119(g)(2)
Refresher training. Refresher training shall be provided at least every three years, and more
often if necessary, to each employee involved in operating a process to assure that the employee
understands and adheres to the current operating procedures of the process. The employer, in
consultation with the employees involved in operating the process, shall determine the
appropriate frequency of refresher training.
1910.119(g)(3)
Training documentation. The employer shall ascertain that each employee involved in operating
a process has received and understood the training required by this paragraph. The employer
shall prepare a record which contains the identity of the employee, the date of training, and the
means used to verify that the employee understood the training.
1910.119(h)
Contractors 1910.119(h)(1)
Application. This paragraph applies to contractors performing maintenance or repair,
turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not
apply to contractors providing incidental services which do not influence process safety, such as
janitorial work, food and drink services, laundry, delivery or other supply services.
1910.119(h)(2)
Employer responsibilities.
1910.119(h)(2)(i)
The employer, when selecting a contractor, shall obtain and evaluate information regarding the
contract employer's safety performance and programs.
1910.119(h)(2)(ii)
The employer shall inform contract employers of the known potential fire, explosion, or toxic
release hazards related to the contractor's work and the process.
1910.119(h)(2)(iii)
The employer shall explain to contract employers the applicable provisions of the emergency
action plan required by paragraph (n) of this section.
1910.119(h)(2)(iv)
The employer shall develop and implement safe work practices consistent with paragraph (f)(4)
of this section, to control the entrance, presence and exit of contract employers and contract
employees in covered process areas.
1910.119(h)(2)(v)
The employer shall periodically evaluate the performance of contract employers in fulfilling their
obligations as specified in paragraph (h)(3) of this section.
1910.119(h)(2)(vi)
The employer shall maintain a contract employee injury and illness log related to the contractor's
work in process areas.
1910.119(h)(3)
Contract employer responsibilities.
1910.119(h)(3)(i)
The contract employer shall assure that each contract employee is trained in the work practices
necessary to safely perform his/her job.
1910.119(h)(3)(ii)
The contract employer shall assure that each contract employee is instructed in the known
potential fire, explosion, or toxic release hazards related to his/her job and the process, and the
applicable provisions of the emergency action plan.
1910.119(h)(3)(iii)
The contract employer shall document that each contract employee has received and understood
the training required by this paragraph. The contract employer shall prepare a record which
contains the identity of the contract employee, the date of training, and the means used to verify
that the employee understood the training.
1910.119(h)(3)(iv)
The contract employer shall assure that each contract employee follows the safety rules of the
facility including the safe work practices required by paragraph (f)(4) of this section.
1910.119(h)(3)(v)
The contract employer shall advise the employer of any unique hazards presented by the
contract employer's work, or of any hazards found by the contract employer's work.
1910.119(i)
Pre-startup safety review.
1910.119(i)(1)
The employer shall perform a pre-startup safety review for new facilities and for modified
facilities when the modification is significant enough to require a change in the process safety
information.
1910.119(i)(2)
The pre-startup safety review shall confirm that prior to the introduction of highly hazardous
chemicals to a process:
1910.119(i)(2)(i)
Construction and equipment is in accordance with design specifications;
1910.119(i)(2)(ii)
Safety, operating, maintenance, and emergency procedures are in place and are adequate;
1910.119(i)(2)(iii)
For new facilities, a process hazard analysis has been performed and recommendations have
been resolved or implemented before startup; and modified facilities meet the requirements
contained in management of change, paragraph (l).
1910.119(i)(2)(iv)
Training of each employee involved in operating a process has been completed.
1910.119(j)
Mechanical integrity —
1910.119(j)(1)
Application. Paragraphs (j)(2) through (j)(6) of this section apply to the following process
equipment:
1910.119(j)(1)(i)
Pressure vessels and storage tanks;
1910.119(j)(1)(ii)
Piping systems (including piping components such as valves);
1910.119(j)(1)(iii)
Relief and vent systems and devices;
1910.119(j)(1)(iv)
Emergency shutdown systems;
1910.119(j)(1)(v)
Controls (including monitoring devices and sensors, alarms, and interlocks) and,
1910.119(j)(1)(vi)
Pumps.
1910.119(j)(2)
Written procedures. The employer shall establish and implement written procedures to maintain
the on-going integrity of process equipment.
1910.119(j)(3)
Training for process maintenance activities. The employer shall train each employee involved in
maintaining the on-going integrity of process equipment in an overview of that process and its
hazards and in the procedures applicable to the employee's job tasks to assure that the employee
can perform the job tasks in a safe manner.
1910.119(j)(4)
Inspection and testing.
1910.119(j)(4)(i)
Inspections and tests shall be performed on process equipment.
1910.119(j)(4)(ii)
Inspection and testing procedures shall follow recognized and generally accepted good
engineering practices.
1910.119(j)(4)(iii)
The frequency of inspections and tests of process equipment shall be consistent with applicable
manufacturers' recommendations and good engineering practices, and more frequently if
determined to be necessary by prior operating experience.
1910.119(j)(4)(iv)
The employer shall document each inspection and test that has been performed on process
equipment. The documentation shall identify the date of the inspection or test, the name of the
person who performed the inspection or test, the serial number or other identifier of the
equipment on which the inspection or test was performed, a description of the inspection or test
performed, and the results of the inspection or test.
1910.119(j)(5)
Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside
acceptable limits (defined by the process safety information in paragraph (d) of this section)
before further use or in a safe and timely manner when necessary means are taken to assure safe
operation.
1910.119(j)(6)
Quality assurance.
1910.119(j)(6)(i)
In the construction of new plants and equipment, the employer shall assure that equipment as it
is fabricated is suitable for the process application for which they will be used.
1910.119(j)(6)(ii)
Appropriate checks and inspections shall be performed to assure that equipment is installed
properly and consistent with design specifications and the manufacturer's instructions.
1910.119(j)(6)(iii)
The employer shall assure that maintenance materials, spare parts and equipment are suitable
for the process application for which they will be used.
1910.119(k)
Hot work permit.
1910.119(k)(1)
The employer shall issue a hot work permit for hot work operations conducted on or near a
covered process.
1910.119(k)(2)
The permit shall document that the fire prevention and protection requirements in 29 CFR
1910.252(a) have been implemented prior to beginning the hot work operations; it shall indicate
the date(s) authorized for hot work; and identify the object on which hot work is to be
performed. The permit shall be kept on file until completion of the hot work operations.
1910.119(l)
Management of change.
1910.119(l)(1)
The employer shall establish and implement written procedures to manage changes (except for
"replacements in kind") to process chemicals, technology, equipment, and procedures; and,
changes to facilities that affect a covered process.
1910.119(l)(2)
The procedures shall assure that the following considerations are addressed prior to any change:
1910.119(l)(2)(i)
The technical basis for the proposed change;
1910.119(l)(2)(ii)
Impact of change on safety and health;
1910.119(l)(2)(iii)
Modifications to operating procedures;
1910.119(l)(2)(iv)
Necessary time period for the change; and,
1910.119(l)(2)(v)
Authorization requirements for the proposed change.
1910.119(l)(3)
Employees involved in operating a process and maintenance and contract employees whose job
tasks will be affected by a change in the process shall be informed of, and trained in, the change
prior to start-up of the process or affected part of the process.
1910.119(l)(4)
If a change covered by this paragraph results in a change in the process safety information
required by paragraph (d) of this section, such information shall be updated accordingly.
1910.119(l)(5)
If a change covered by this paragraph results in a change in the operating procedures or practices
required by paragraph (f) of this section, such procedures or practices shall be updated
accordingly.
1910.119(m)
Incident investigation.
1910.119(m)(1)
The employer shall investigate each incident which resulted in, or could reasonably have resulted
in a catastrophic release of highly hazardous chemical in the workplace.
1910.119(m)(2)
An incident investigation shall be initiated as promptly as possible, but not later than 48 hours
following the incident.
1910.119(m)(3)
An incident investigation team shall be established and consist of at least one person
knowledgeable in the process involved, including a contract employee if the incident involved
work of the contractor, and other persons with appropriate knowledge and experience to
thoroughly investigate and analyze the incident.
1910.119(m)(4)
A report shall be prepared at the conclusion of the investigation which includes at a minimum:
1910.119(m)(4)(i)
Date of incident;
1910.119(m)(4)(ii)
Date investigation began;
1910.119(m)(4)(iii)
A description of the incident;
1910.119(m)(4)(iv)
The factors that contributed to the incident; and,
1910.119(m)(4)(v)
Any recommendations resulting from the investigation.
1910.119(m)(5)
The employer shall establish a system to promptly address and resolve the incident report
findings and recommendations. Resolutions and corrective actions shall be documented.
1910.119(m)(6)
The report shall be reviewed with all affected personnel whose job tasks are relevant to the
incident findings including contract employees where applicable.
1910.119(m)(7)
Incident investigation reports shall be retained for five years.
1910.119(n)
Emergency planning and response. The employer shall establish and implement an emergency
action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition,
the emergency action plan shall include procedures for handling small releases. Employers
covered under this standard may also be subject to the hazardous waste and emergency
response provisions contained in 29 CFR 1910.120 (a), (p) and (q).
1910.119(o)
Compliance Audits.
1910.119(o)(1)
Employers shall certify that they have evaluated compliance with the provisions of this section at
least every three years to verify that the procedures and practices developed under the standard
are adequate and are being followed.
1910.119(o)(2)
The compliance audit shall be conducted by at least one person knowledgeable in the process.
1910.119(o)(3)
A report of the findings of the audit shall be developed.
1910.119(o)(4)
The employer shall promptly determine and document an appropriate response to each of the
findings of the compliance audit, and document that deficiencies have been corrected.
1910.119(o)(5)
Employers shall retain the two (2) most recent compliance audit reports.
1910.119(p)
Trade secrets.
1910.119(p)(1)
Employers shall make all information necessary to comply with the section available to those
persons responsible for compiling the process safety information (required by paragraph (d) of
this section), those assisting in the development of the process hazard analysis (required by
paragraph (e) of this section), those responsible for developing the operating procedures
(required by paragraph (f) of this section), and those involved in incident investigations
(required by paragraph (m) of this section), emergency planning and response (paragraph (n) of
this section) and compliance audits (paragraph (o) of this section) without regard to possible
trade secret status of such information.
1910.119(p)(2)
Nothing in this paragraph shall preclude the employer from requiring the persons to whom the
information is made available under paragraph (p)(1) of this section to enter into confidentiality
agreements not to disclose the information as set forth in 29 CFR 1910.1200.
1910.119(p)(3)
Subject to the rules and procedures set forth in 29 CFR 1910.1200(i)(1) through
1910.1200(i)(12), employees and their designated representatives shall have access to trade
secret information contained within the process hazard analysis and other documents required
to be developed by this standard.
[57 FR 23060, June 1, 1992; 61 FR 9227, March 7, 1996; 77 FR 17776, March 26, 2012; 78 FR
9313, Feb. 8, 2013]

Standard Number:
1910.119
NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is
presented here as historical content, for research and review purposes only.
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain
these requirements and how they apply to particular circumstances, but they cannot create additional
employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note
that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we
update our guidance in response to new information. To keep apprised of such developments, you can
consult OSHA's website at https://www.osha.gov.
This Interpretation no longer represents OSHA Policy- The updated Document can be found
here RAGAGEP in Process Safety Management Enforcement 5/11/2016
June 5, 2015
MEMORANDUM FOR:
REGIONAL ADMINISTRATORS AND STATE PLAN DESIGNE
THROUGH:
DOROTHY DOUGHERTY
Deputy Assistant Secretary
FROM:
THOMAS GALASSI Director
Directorate of Enforcement Programs
RAGAGEP in Process Safety Management Enforcement
SUBJECT:
This memorandum provides guidance on the enforcement of the Process Safety Management
(PSM) Standard's recognized and generally accepted good engineering practices (RAGAGEP)
requirements, including how to interpret "shall" and "should" language in published codes,
standards, published technical reports, recommended practices (RP) or similar documents, and
on the use of internal employer documents as RAGAGEP. Enforcement activity, including
the Petroleum Refinery Process Safety Management National Emphasis Program (Refinery NEP),
and requests for assistance from the field, revealed the need for guidance on the PSM standard's
RAGAGEP provisions.
Background on Recognized and Generally Accepted Good Engineering Practices
The PSM Standard, 29 CFR 1910.119, directly references or implies the use of RAGAGEP in three
provisions:
(d)(3)(ii): Employers must document that all equipment in PSM-covered processes
complies with RAGAGEP;
 (j)(4)(ii): Inspections and tests are performed on process equipment subject to the
standard's mechanical integrity requirements in accordance with RAGAGEP; and
 (j)(4)(iii): Inspection and test frequency follows manufacturer's recommendations and
good engineering practice, and more frequently if indicated by operating experience.
In addition, (d)(3)(iii) addresses situations where the design codes, standards, or practices used
in the design and construction of existing equipment are no longer in general use.

The PSM standard does not define RAGAGEP. However, the Refinery National Emphasis Program
(CPL 03-00-010) references the definition found in the Center for Chemical Process Safety's
(CCPS) Guidelines for Mechanical Integrity Systems:
"Recognized And Generally Accepted Good Engineering Practices" (RAGAGEP) - are the basis for
engineering, operation, or maintenance activities and are themselves based on established codes,
standards, published technical reports or recommended practices (RP) or similar documents.
RAGAGEP detail generally approved ways to perform specific engineering, inspection or
mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or servicing
a relief valve.
As used in the PSM standard, RAGAGEP apply to process equipment design, installation,
operation, and maintenance; inspection and test practices; and inspection and test frequencies.
RAGAGEP must be both "recognized and generally accepted" and "good engineering" practices.
The PSM standard allows employers to select the RAGAGEP they apply in their covered processes
.
Primary Sources of RAGAGEP
1. Published and widely adopted codes
Certain consensus standards have been widely adopted by federal, state, or municipal
jurisdictions. For example, many state and municipal building and other codes incorporate
or adopt codes such as the National Fire Protection Association (NFPA) 101 Life Safety and
NFPA 70 National Electric codes. Such published and widely accepted codes are generally
accepted by OSHA as RAGAGEP, as are Federal, state, and municipal laws and regulations
serving the same purposes.
2. Published consensus documents
Certain organizations like the American Society of Mechanical Engineers (ASME) follow
the American National Standards Institute's (ANSI) Essential Requirements: Due process
requirements for American National Standards (Essential Requirements) when publishing
consensus standards and recommended practices. Under the ANSI and similar
requirements, these organizations must demonstrate that they have diverse and broadly
representative committee memberships. Examples of published consensus documents
include the ASME B31.3 Process Piping Code and the International Institute of Ammonia
Refrigeration's (IIAR) ANSI/IIAR 2-2008 - Equipment, Design, and Installation of ClosedCircuit Ammonia Mechanical Refrigerating Systems. Published consensus documents are
very widely used as RAGAGEP by those knowledgeable in the industry, and are accepted as
RAGAGEP by OSHA.
3. Published non-consensus documents
Some industries publish non-consensus engineering documents using processes not
conforming to ANSI's Essential Requirements. For example, the Chlorine Institute's (CI)
"pamphlets" focus on chlorine and sodium hypochlorite (bleach) safety. Where applicable,
the practices described in these documents are widely accepted as good practices and used
in industries handling these materials. Similarly, CCPS publishes an extensive set of
guideline books, some, but not all, of which deal with process equipment specific topics,
e.g., the Design Institute for Emergency Relief Systems' technology for reactive and multiphase relief systems design1. Peer-reviewed technical articles addressing specific hazards
may also fall into this category and may be considered when published standards or
recommended practices are not available or are not adequate to address specific hazards.
OSHA may accept such materials as RAGAGEP where applicable and appropriate.
Note that 29 CFR 1910.119(j)(4)(iii) also recognizes applicable manufacturer's
recommendations as potential sources of RAGAGEP.
"Appropriate Internal Standards"
The preamble to the PSM standard recognizes that employers may develop internal standards for
use within their facilities. The preamble states, in relevant part:
The phrase suggested by rulemaking participants: "recognized and generally accepted good
engineering practices" is consistent with OSHA's intent. The Agency also believes that this phrase
would include appropriate internal standards of a facility . . .2 [emphasis added].
The preamble, however, does not imply that employers may disregard applicable published
RAGAGEP.3 Internally developed standards must still represent "recognized and generally
accepted good engineering practices."
Facility internal standards can serve a number of legitimate purposes, including:
1. Translating the requirements of published RAGAGEP into detailed corporate or facility
implementation programs and/or procedures.
2. Setting design, installation, maintenance, inspection, and testing requirements for unique
processes, equipment, and hazards for which no published RAGAGEP exists.
3. Supplementing (or augmenting) published RAGAGEP that only partially or inadequately
address the employer's processes, occupancies, conditions, and hazards. In this situation
OSHA (and often the publisher) expect employers/users to supplement the published
RAGAGEP with their own applicable practices, protocols, and procedures to control
hazards.4
4. Controlling hazards more effectively than the available codes, standards, or practices.
5. Addressing hazards when the codes and standards used for existing equipment are
outdated and no longer describe good engineering practice.
Employers' internal standards must either meet or exceed the protective requirements of
published RAGAGEP where such RAGAGEP exist. OSHA has rejected employer standards that
deviated from published RAGAGEP where the deviations were less protective than the published
requirements.
"Shall" and "Should" in RAGAGEP
"Shall," "must," or similar language used in published RAGAGEP reflects the developer's view that
the practice is a mandatory minimum requirement to control a hazard. Similarly, "shall not,"
"prohibited," or similar language references or describes unacceptable approaches or practices. If
an employer deviates from "shall" or "shall not" requirements in the employer's adopted
RAGAGEP (or applicable RAGAGEP if the employer has not specified RAGAGEP), OSHA will
presume a violation.
Use of the term "should" or similar language in the RAGAGEP reflects an acceptable and preferred
approach, in the view of the publishing group, to controlling a recognized hazard. If a selected
RAGAGEP provision is applicable to the covered process or particular situation, OSHA presumes
that employer compliance with the recommended approach is acceptable.
If an employer chooses to use an alternate approach to the one the published "should" RAGAGEP
says applies, the CSHO should evaluate whether the employer has determined and documented
that the alternate approach is at least as protective, or that the published RAGAGEP is not
applicable to the employer's operation. In the absence of such documentation, the CSHO should
examine documents, such as relevant process hazards analyses (PHAs) and management of
change procedures (MOCs), to determine if the employer's approach is as protective as the
published RAGAGEP and is a good engineering practice. This may require consultation with
Regional resources or the OSHA National Office (see below).
"Should not" or similar language describes disfavored or less than fully protective practices.
Following such disfavored practices is presumed to be violative.
For technical help, consult with your Regional PSM Coordinator, technical support engineer, or
contact the PSM group at OSHA's Directorate of Enforcement Programs - Office of Chemical
Process Safety and Enforcement Initiatives at 202-693-2341.
"Normative" and "Informative" Requirements.
Published codes and consensus documents frequently contain appendices or annexes that
provide supplemental information and/or requirements. The content of these appendices or
annexes may be "normative" or "informative." "Normative" sections generally explain how to
comply with the published code and/or consensus document requirements and may contain both
"shall" and "should" language. As discussed above, "shall" denotes the developer's view that the
normative statement is mandatory, while "should" indicates an acceptable or preferred
approach. "Informative" sections generally provide background and reference information with
respect to the published code and/or consensus document requirements but may also identify
and/or address hazards or acceptable means of abatement. Again, for technical help, CSHOs
should consult their Regional PSM coordinator, technical support engineer, or the Office of
Chemical Process Safety and Enforcement Initiatives.
Other Uses of RAGAGEP Materials in PSM
Only the three sections of 1910.119 referenced above require compliance with RAGAGEP.
However, RAGAGEP can also provide useful background and context, and can help CSHOs identify
and document hazards and feasible means of abatement when reviewing other aspects of the
employer's PSM program and covered equipment.
Enforcement considerations
In accordance with 1910.119, employers select the RAGAGEP with which their equipment and
procedures must comply. In evaluating RAGAGEP compliance, CSHOs should be aware of a
number of potential issues:
1. There may be multiple RAGAGEP that apply to a specific process. For example, American
Petroleum Institute (API), RP 520 Sizing, Selection, and Installation of Pressure-Relieving
Devices in Refineries Part II - Installation, and International Standards Organization,
Standard No. 4126-9, Application and installation of safety devices, are both RAGAGEP for
relief valve installation and contain similar but not identical requirements. Both
documents are protective and either is acceptable to OSHA.
2. Employers do not need to consider or comply with a RAGAGEP provision that is not
applicable to their specific worksite conditions, situations, or applications.
3. Some employers apply RAGAGEP outside of their intended area of application, such as
using ammonia refrigeration pressure vessel inspection recommended practices in a
chemical plant or refinery process. Use of inapplicable RAGAGEP can result in poor hazard
control and can be grounds for citations.
4. There may be cases where fully applicable RAGAGEP do not exist to control hazards in an
employer's covered process. As discussed in "Appropriate Internal Standards", above, the
employer's internal standards (guidance and procedures) are expected to address the
process hazards. Whether the internal standards are adequately protective should be
reviewed on a case-by-case basis.
5. An employer's internal standards may be more stringent than the relevant published
RAGAGEP. More-stringent standards may be needed to adequately control hazards due to
the unique characteristics of the employer's process. This should be documented.
Employers that meet published RAGAGEP requirements, but that fail to comply with their
own more stringent internal requirements, may be citable under other PSM provisions:
 If there is a failure to follow more stringent internal Inspection & Test (I&T)
procedures, consider citations under 1910.119(j)(2) for failure to implement their
written I&T procedures
 Process equipment may be outside acceptable limits defined in the employer's PSI. If
so, consider citations under 1910.119(j)(5).
 Additional or more stringent equipment safeguards may be specified by employers
based on findings and recommendations from PHAs and supporting documents,
such as Layers of Protection Analyses, siting studies, human factors studies,
Quantitative Risk Assessments, and similar risk management activities, as well as
Incident Investigations, or Management of Change procedures. Failure to implement
or complete documented actions-to-be-taken may be cited under the relevant
section of the Standard (e.g., 1910.119(e), (l), or (m)).
6. Selectively applying individual provisions from multiple RAGAGEP addressing similar
hazards might be inappropriate. Standard writing organizations develop their
requirements as packages and mixing-and-matching provisions from multiple sources
could result in inadequately controlled hazards. This situation should be evaluated on a
case-by-case basis. Consult the regional PSM Coordinator, regional engineering support, or
the Office of Chemical Process Safety and Enforcement Initiatives if you are uncertain how
to proceed.
7. The PSM standard requires employers to document that their inspection and testing of
equipment, required under 1910.119(j)(4)(ii) and (iii), is in accordance with their
selected RAGAGEP, (e.g., as referenced in the written procedures required by
1910.119(j)(2)). Failure to do so is citable.
8. In accordance with 1910.119(d)(3)(ii), employers must document that their covered
process equipment and equipment whose operation could affect that process equipment
comply with RAGAGEP (equipment built to older standards may come under
1910.119(d)(3)(iii), see paragraph 10 below). Equipment that does not comply with
RAGAGEP cannot be documented as compliant. Therefore, both the failure to document
compliance and the deviations from compliance with RAGAGEP can be cited under
(d)(3)(ii).
When writing 1910.119(d)(3)(ii) RAGAGEP-related citations, always cite the employer
for failing to document compliance with recognized and generally accepted good
engineering practices, describe the hazard, e.g., exposure of employees to fire, explosion,
or toxic hazards, and reference the RAGAGEP selected by the employer. If the employer has
not specified an applicable RAGAGEP, use "such as" language to reference an applicable
published RAGAGEP.
9. Equipment covered under PSM's Mechanical Integrity provisions (listed in 1910.119(j))
that is outside acceptable limits, as defined by the process safety information (including
RAGAGEP), is deficient under 1910.119(j)(5). Employers are required by this provision to
correct deficiencies before further use or in a safe and timely manner when necessary
means are taken to assure safe operation in the interim. If an employer fails to correct the
deficiency before further use, or fails to implement adequate interim measures and to
schedule a permanent correction timely, the failure may be cited under 1910.119(j)(5). If
an employer has implemented interim measures and scheduled correction, additional
investigation may be required to determine whether the interim measures are adequate
and the scheduled correction is timely. 1910.119(d)(3)(ii) and (j)(5) citations are often
grouped. Consult your Regional OSHA support staff and/or SOL if you are uncertain if
grouped citations are appropriate.
Note, in the case where an employer is operating deficient equipment based on the use of
interim safeguards pending final correction of the deficiency, 29 CFR 1910.119(l) requires
that the employer develop and implement a management-of-change procedure for the
continued safe operation of the equipment.
10. Older covered equipment may not have been designed and constructed under an
applicable RAGAGEP because none existed at the time of design and construction.
Alternatively, the equipment may have been designed and constructed under provisions of
codes, standards, or practices that are no longer in general use. In such cases, 29 CFR
1910.119(d)(3)(iii) requires employers to determine and document that the equipment is
designed, maintained, inspected, tested, and operating in a safe manner. Failure to do so
may be cited under 1910.119(d)(3)(iii).
When writing 1910.119(d)(3)(iii) citations, always cite the employer for failing to
determine and document that the relevant equipment design, maintenance, inspection and
testing, and/or operation ensure the safety of the equipment.
If the employer has adopted an appropriate internal standard applicable to such older
equipment, 29 CFR 1910.119(d)(3)(ii) requires the employer to document that the
equipment complies with the internal standard. Failure to do so may result in a citation
under 29 CFR 1910.119(d)(3)(ii).
11. When a 29 CFR 1910.119(d)(3)(ii) or (iii) citation is under consideration, it is important
to establish and to document the age and installation date of the relevant process and
equipment, and the dates and extent of process and equipment modifications, as well as
the exact RAGAGEP selected by the employer, including the edition and publication date.
12. Organizations that publish RAGAGEP may update them based on newly identified or
recognized hazards; improved understanding of existing hazards; industry operating
experience; and/or incidents indicating that more stringent hazard control is needed. If
the updated RAGAGEP explicitly provides that new clauses or requirements are
retroactive, OSHA expects employers that have selected that RAGAGEP to conform to those
provisions. Where RAGAGEP are updated to be more protective but are not explicitly
retroactive, PSM does not mandate that employers upgrade their equipment, facilities, or
practices to meet current versions of their selected RAGAGEP. However, OSHA does expect
employers to address issues raised by or identified in the updated RAGAGEP in accordance
with 1910.119(d)(3)(iii) by determining and documenting that their equipment is
designed, maintained, inspected, tested, and operating in a safe manner. This can be
accomplished through a variety of approaches, such as but not limited to the PHA
revalidation and management of change (MOC) processes, or through corporate
monitoring and review of published standards. Citations for 29 CFR 1910.119(d)(3)(iii),
either stand-alone or grouped with, for example, (e)(3) or (l)(1), may be appropriate if the
employer fails to address the issues (see item 8 above).
13. Notify the Office of Chemical Process Safety and Enforcement Initiatives if you encounter
RAGAGEP that appear to have changed to be less protective or that are being interpreted
by employers in a manner that is less protective. In the past, OSHA determined that
specific provisions in published guidance documents were not RAGAGEP (i.e., OSHA
believed that some written practices provided inadequate protection and were not good
engineering practices; therefore, the specific practices in question could not be RAGAGEP).
Such determinations should only be made in consultation with the Office of Chemical
Process Safety and Enforcement Initiatives.
14. When writing 1910.119(j)(4)(ii) citations, always cite the employer for failing to follow
RAGAGEP in its inspection and testing procedures, and reference the relevant RAGAGEP
adopted / recognized by the employer. If the employer has not specified an applicable
RAGAGEP, use "such as" language to reference an applicable published RAGAGEP. When
the employer's I&T procedures comply with RAGAGEP, but are not implemented or
followed, consider 1910.119(j)(2) citations.
15. When writing 1910.119(j)(4)(iii) citations, always cite the employer for not inspecting
and/or testing process equipment at frequencies consistent with applicable
manufacturers' recommendations and good engineering practices, or more frequently if
indicated by prior operating experience, i.e., based on the condition of the equipment when
previously inspected or tested.
16. When writing RAGAGEP-related citations when the employer has not specified a
RAGAGEP, CSHOs should be careful to reference in the citation's alleged violation
description only RAGAGEP that are actually applicable to the equipment and process being
inspected. CSHOs have sometimes referenced inapplicable API relief valve RAGAGEP in
citations involving ammonia refrigeration processes.
1 Many CCPS publications deal with management system issues and do not address topics subject
to RAGAGEP.
2 PSM preamble accessed
at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=PREAMBLES&p_id=1
041 on January 15, 2013.
3 29 CFR 1910.119 Purpose; 57 Fed. Reg. 6390.
4 For example: ANSI/IIAR 2-2008 Equipment, Design, and Installation of Closed-Circuit Ammonia
Mechanical Refrigerating Systems states, "This document is intended to serve as a standard for
equipment, design and installation of closed circuit ammonia refrigerating systems. Additional
requirements may be necessary because of particular circumstances, project specifications or
other jurisdictional considerations. Note that this standard does not constitute a comprehensive
detailed technical design manual and should not be used as such . . ." (pg. i).

Standard Number:
1910.119
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain
these requirements and how they apply to particular circumstances, but they cannot create additional
employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note
that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we
update our guidance in response to new information. To keep apprised of such developments, you can
consult OSHA's website at https://www.osha.gov.
May 11, 2016
MEMORANDUM FOR:
REGIONAL ADMINISTRATORS
THROUGH:
DOROTHY DOUGHERTY
Deputy Assistant Secretary
FROM:
THOMAS M. GALASSI, Director
Directorate of Enforcement Programs
SUBJECT:
RAGAGEP in Process Safety Management Enforcement
This enforcement policy addresses the Process Safety Management (PSM) Standard's recognized
and generally accepted good engineering practices (RAGAGEP) requirements. Enforcement
activity, including the Petroleum Refinery Process Safety Management National Emphasis
Program (Refinery NEP), and requests for assistance from the field, revealed the need for this
guidance. This memorandum rescinds and replaces the memorandum of the same title dated
June 5, 2015. It is intended to be a clarification of the policy described in the earlier
memorandum and does not reflect any substantive change in OSHA enforcement policy.
Background on Recognized and Generally Accepted Good Engineering Practices
The PSM Standard, 29 CFR 1910.119, directly references or implies the use of RAGAGEP in three
provisions:
(d)(3)(ii): Employers must document that all equipment in PSM-covered processes
complies with RAGAGEP;
 (j)(4)(ii): Inspections and tests are performed on process equipment subject to the
standard's mechanical integrity requirements in accordance with RAGAGEP; and
 (j)(4)(iii): Inspection and test frequency follows manufacturer's recommendations and
good engineering practice, and more frequently if indicated by operating experience.
In addition, (d)(3)(iii) addresses situations where the design codes, standards, or practices used
in the design and construction of existing equipment are no longer in general use. In such cases,
the employer must determine and document that the equipment is designed, maintained,
inspected, tested, and operating in a safe manner.

As used in the PSM standard, RAGAGEP apply to process equipment design and maintenance;
inspection and test practices; and inspection and test frequencies.
Examples of RAGAGEP
1. Widely adopted codes
Certain consensus standards have been widely adopted by federal, state, or municipal
jurisdictions. For example, many state and municipal building and other codes incorporate
or adopt codes such as the National Fire Protection Association (NFPA) 101 Life Safety and
NFPA 70 National Electric codes.
2. Consensus documents
Certain organizations like the American Society of Mechanical Engineers (ASME) follow
the American National Standards Institute's (ANSI) Essential Requirements: Due process
requirements for American National Standards (Essential Requirements) when developing
consensus standards and recommended practices. Under the ANSI and similar
requirements, these organizations must demonstrate that they have diverse and broadly
representative committee memberships. Examples of consensus documents include the
ASME B31.3 Process Piping Code and the International Institute of Ammonia
Refrigeration's (IIAR) ANSI/IIAR 2-2008 — Equipment, Design, and Installation of ClosedCircuit Ammonia Mechanical Refrigerating Systems. Such consensus documents are widely
used as sources of RAGAGEP by those knowledgeable in the industry.
3. Non-consensus documents
Some industries develop non-consensus engineering documents using processes not
conforming to ANSI's Essential Requirements. Where applicable, the practices described in
these documents can be widely accepted as good practices. For example, the Chlorine
Institute's (CI) "pamphlets" focus on chlorine and sodium hypochlorite (bleach) safety and
are used by some companies handling these materials. Note that OSHA also recognizes
applicable manufacturer's recommendations as potential sources of RAGAGEP.
4. Internal standards
The preamble to the PSM standard recognizes that employers may develop internal
standards for use within their facilities. The preamble states, in relevant part:
The phrase suggested by rulemaking participants: "recognized and generally
accepted good engineering practices" is consistent with OSHA's intent. The Agency
also believes that this phrase would include appropriate internal standards of a
facility . . . .(1)
Internally developed standards must still represent recognized and generally
accepted good engineering practices.

Reasons an employer might choose to follow internal standards can include:
1. Translating the requirements of published RAGAGEP into detailed corporate or facility
implementation programs and/or procedures.
2. Setting design, maintenance, inspection, and testing requirements for unique equipment
for which no other RAGAGEP exists.
3. Supplementing or augmenting RAGAGEP selected by the employer that only partially or
inadequately address the employer's equipment.
4. Controlling hazards more effectively than the available codes and consensus and/or nonconsensus documents when deemed necessary by the employer's PSM program.
5. Addressing hazards when the codes and consensus and/or non-consensus documents
used for existing equipment are outdated and no longer describe good engineering
practice.
In keeping with the performance-oriented nature of the PSM standard, employers select the
RAGAGEP they apply in their covered processes. The examples of RAGAGEP noted above are not
intended to reflect a hierarchy of RAGAGEP.
If an employer selects and follows widely adopted codes or consensus documents or widely
adopted non-consensus documents for RAGAGEP, OSHA will accept such materials as RAGAGEP
where applicable and appropriate.
If an employer develops and follows internal procedures, the compliance safety and health officer
(CSHO) should assess whether the internal procedures represent recognized and generally
accepted good engineering practices. Like all employers complying with the PSM standard, an
employer using internal procedures as RAGAGEP has an obligation under 1910.119(d)(3)(ii) to
document that its equipment complies with recognized and generally accepted good engineering
practices.
For technical help, consult with the Regional PSM Coordinator, a technical support engineer, or
the PSM group at OSHA's Directorate of Enforcement Programs - Office of Chemical Process
Safety and Enforcement Initiatives at 202-693-2341.
"Shall" and "Should" in RAGAGEP
"Shall," "must," or similar language used in RAGAGEP reflects the developer's view that the
practice is a mandatory minimum requirement to control a hazard. Similarly, "shall not,"
"prohibited," or similar language references or describes unacceptable approaches or practices. If
an employer deviates from an applicable "shall" or "shall not" requirement in the employer's
adopted RAGAGEP, OSHA will presume a violation. In accordance with the inspection procedures
described in Chapter 3 of OSHA's Field Operations Manual (CPL 02-00-159, Oct. 1, 2015), the
employer will have an opportunity to explain the rationale for the deviation and why it believes
its approach reflects recognized and generally accepted goodengineering practices.
Use of the term "should" or similar language in RAGAGEP denotes a recommendation that
reflects an acceptable and preferred practice. If a "should" provision in the employer's selected
RAGAGEP is applicable to the covered process or particular situation, OSHA presumes that
employer compliance with the recommended approach is acceptable.
If an employer selects RAGAGEP that contains "should" provisions, but does not follow them,
OSHA will not presume a violation. In such cases, the CSHO should evaluate whether the
employer's approach reflects recognized and generally accepted goodengineering practices and
whether the employer documented that its equipment complies with RAGAGEP. An employer
does not need to document deviations from a "should" statement provided it documents that its
equipment complies with RAGAGEP.
If an employer selects RAGAGEP that contains "should not" provisions (or similar language
describing disfavored practices), and then follows the disfavored practices, OSHA will not
presume a violation. In such cases, the CSHO should evaluate whether the employer's approach
reflects recognized and generally accepted good engineering practices and whether the employer
documented that its equipment complies with RAGAGEP. An employer does not need to
document deviations from a "should not" statement provided it documents that its equipment
complies with RAGAGEP.
For technical help, consult with your Regional PSM Coordinator, a technical support engineer, or
the PSM group at OSHA's Directorate of Enforcement Programs - Office of Chemical Process
Safety and Enforcement Initiatives at 202-693-2341.
"Normative" and "Informative" Requirements in RAGAGEP
Codes and consensus documents frequently contain appendices or annexes that provide
supplemental information and/or requirements. The content of these appendices or annexes
may be "normative" or "informative." "Normative" sections generally explain how to comply with
the code and/or consensus document requirements and may contain both "shall" and "should"
language. As discussed above, "shall" denotes the developer's view that the normative statement
is mandatory, while "should" indicates a recommendation that reflects an acceptable and
preferred practice. "Informative" sections generally provide background and reference
information with respect to the code and/or consensus document requirements but may also
identify and/or address hazards or acceptable means of abatement. Employers should read and
consider these sections, but OSHA does not expect employers to consult all of the sources that are
cited in an informative section or appendix. Again, for technical help, CSHOs should consult their
Regional PSM coordinator, technical support engineer, or the Office of Chemical Process Safety
and Enforcement Initiatives.
Enforcement Considerations
Under 1910.119, employers select the RAGAGEP with which their equipment and procedures
must comply. In evaluating RAGAGEP compliance, CSHOs should be aware of a number of
potential issues:
1. There may be multiple RAGAGEP that apply to a specific process. For example, American
Petroleum Institute (API), RP 520 Sizing, Selection, and Installation of Pressure-Relieving
Devices in Refineries Part II - Installation, and International Standards Organization,
Standard No. 4126-9, Application and installation of safety devices, are both RAGAGEP for
relief valve installation and contain similar but not identical requirements. Both
documents are protective and either is acceptable to OSHA.
2. Employers do not need to consider or comply with a RAGAGEP provision that is not
applicable to their specific worksite conditions, situations, or applications.
3. Some employers apply RAGAGEP outside of their intended area of application, such as
using ammonia refrigeration pressure vessel inspection recommended practices in a
chemical plant or refinery process. Use of inapplicable RAGAGEP can result in poor hazard
control and can be grounds for citations.
4. There may be cases where the selected RAGAGEP does not control all of the hazards in an
employer's covered process. As discussed above, the employer is expected to adopt other
RAGAGEP (potentially including internal standards, guidance, or procedures) to address
remaining process hazards. Whether internal standards constitute RAGAGEP should be
reviewed on a case-by-case basis.
5. An employer's internal standards may be more stringent than other relevant sources of
RAGAGEP. More-stringent standards may be needed to adequately control hazards due to
the unique characteristics of the employer's process. In all cases the employer must
document that its equipment complies with recognized and generally accepted good
engineering practices. Employers that meet the requirements of other applicable sources
of RAGAGEP, but fail to comply with their own more stringent internal requirements, may
be citable under other PSM provisions:
If there is a failure to follow more stringent internal Inspection & Test (I&T)
procedures, consider citations under 1910.119(j)(2) for failure to implement their
written I&T procedures
 Process equipment may be outside acceptable limits defined in the employer's PSI. If
so, consider citations under 1910.119(j)(5).
 Additional or more stringent equipment safeguards may be specified by employers
based on findings and recommendations from PHAs, Incident Investigations, or
Management of Change procedures. Failure to implement or complete documented
actions-to-be-taken may be cited under the relevant section of the Standard (e.g.,
1910.119(e), (l), or (m)).
6. Selectively applying individual provisions from multiple RAGAGEP addressing similar
hazards might be inappropriate. Standard writing organizations develop their
requirements as packages and mixing-and-matching provisions from multiple sources
could result in inadequately controlled hazards. Internal standards that incorporate select
provisions from different sources of RAGAGEP may in some circumstances be appropriate,
or may be more protective than applying one source of RAGAGEP. This situation should be
evaluated on a case-by-case basis. Consult the regional PSM Coordinator, regional

engineering support, or the Office of Chemical Process Safety and Enforcement Initiatives
if you are uncertain how to proceed.
7. The PSM standard at 1910.119(j)(4)(ii) requires employers to follow RAGAGEP in
establishing and implementing inspection and testing procedures. At 1910.119(j)(4)(iii),
the standard provides that the frequency of inspections and tests of process equipment
must be consistent with applicable manufacturers' recommendations and good
engineering practices, and that inspections and tests must be performed more frequently if
determined to be necessary by prior operating experience. CSHOs should review relevant
documents, such as the employer's written inspection and test procedures (required
under 1910.119(j)(2)), to determine the employer's selected RAGAGEP.
8. In accordance with 1910.119(d)(3)(ii), employers must document that their covered
process equipment complies with RAGAGEP (equipment built to older standards may
come under 1910.119(d)(3)(iii), see paragraph 10 below). Equipment that does not
comply with RAGAGEP cannot be documented as compliant. Therefore, both the failure to
document compliance and the deviations from compliance with RAGAGEP can be the basis
for citations under 1910.119(d)(3)(ii) (see procedures for combining and grouping
violations in Chapter 4 of the Field Operations Manual (CPL 02-00-159, Oct. 1, 2015)).
Note that the documentation requirement in 1910.119(d)(3)(ii) does not require the
employer to document all of its engineering judgments.
When writing 1910.119(d)(3)(ii) RAGAGEP-related citations, always cite the employer
for failing to document compliance with recognized and generally accepted good
engineering practices, describe the hazard, e.g., exposure of employees to fire, explosion,
or toxic hazards, and reference the RAGAGEP selected by the employer. If the employer has
not specified an applicable RAGAGEP, use "such as" language to reference an applicable
source of RAGAGEP.
9. Equipment covered under PSM's Mechanical Integrity provisions (listed in 1910.119(j))
that is outside acceptable limits, as defined by the process safety information (including
RAGAGEP), is deficient under 1910.119(j)(5). Employers are required by this provision to
correct deficiencies before further use or in a safe and timely manner when necessary
means are taken to assure safe operation in the interim. If an employer fails to correct the
deficiency before further use, or fails to assure safe operation and schedule a permanent
correction timely, the failure may be cited under 1910.119(j)(5). If an employer has
implemented interim measures and scheduled correction, additional investigation may be
required to determine whether the employer has assured safe operation and the
scheduled correction is timely. 1910.119(d)(3)(ii) and (j)(5) citations are often grouped.
Consult your Regional OSHA support staff and/or SOL if you are uncertain if grouped
citations are appropriate.
Note, in the case where an employer is operating deficient equipment based on the use of
interim safeguards pending final correction of the deficiency, the employer must develop
and implement a management of change procedure for the continued safe operation of the
equipment when required by 29 CFR 1910.119(l).
10. Older covered equipment may not have been designed and constructed under an
applicable RAGAGEP because none existed at the time of design and construction.
Alternatively, the equipment may have been designed and constructed under provisions of
codes, standards, or practices that are no longer in general use. In such cases, 29 CFR
1910.119(d)(3)(iii) requires employers to determine and document that the equipment is
designed, maintained, inspected, tested, and operating in a safe manner. Failure to do so
may be cited under 1910.119(d)(3)(iii).
When writing 1910.119(d)(3)(iii) citations, always cite the employer for failing to
determine and document that the relevant equipment is designed, maintained, inspected,
tested, and operating in a safe manner.
If the employer has adopted an appropriate internal standard applicable to such older
equipment, 29 CFR 1910.119(d)(3)(ii) requires the employer to document that the
equipment complies with the internal standard. Failure to do so may result in a citation
under 29 CFR 1910.119(d)(3)(ii).
11. When a 29 CFR 1910.119(d)(3)(ii) or (iii) citation is under consideration, it is important
to establish and to document the age and installation date of the relevant process and
equipment, and the dates and extent of process and equipment modifications, as well as
the RAGAGEP selected by the employer, including the edition and publication date.
12. Organizations that develop codes and consensus and/or non-consensus documents may
update them based on newly identified or recognized hazards; improved understanding of
existing hazards; industry operating experience; and/or incidents indicating that more
stringent hazard control is needed. If the updated document explicitly provides that new
clauses or requirements are retroactive, those updates are relevant to determining
whether the employer's practice continues to conform to RAGAGEP. Where RAGAGEP are
updated to be more protective but are not explicitly retroactive, PSM does not mandate
that employers upgrade their equipment, facilities, or practices to meet current versions of
their selected RAGAGEP. However, under 1910.119(d)(3)(iii), employers must determine
and document that their equipment is designed, maintained, inspected, tested, and
operating in a safe manner.
13. Notify the Office of Chemical Process Safety and Enforcement Initiatives if you encounter
sources of RAGAGEP that appear to have changed to be less protective or that are being
interpreted by employers in a manner that is less protective. There have been times in the
past when OSHA has determined that specific provisions in published guidance documents
no longer reflect generally accepted and good engineering practices. Such determinations
should only be made in consultation with the Office of Chemical Process Safety and
Enforcement Initiatives.
14. When writing 1910.119(j)(4)(ii) citations, always cite the employer for failing to follow
RAGAGEP in its inspection and testing procedures, and reference the relevant RAGAGEP
adopted / recognized by the employer. If the employer has not specified an applicable
RAGAGEP, use "such as" language to reference an applicable source of RAGAGEP. When the
employer's I&T procedures comply with RAGAGEP, but are not implemented or followed,
consider 1910.119(j)(2) citations.
15. When writing 1910.119(j)(4)(iii) citations, always cite the employer for not inspecting
and/or testing process equipment at frequencies consistent with applicable
manufacturers' recommendations and good engineering practices, or more frequently if
indicated by prior operating experience, i.e., based on the condition of the equipment when
previously inspected or tested.
16. When writing RAGAGEP-related citations when the employer has not specified a
RAGAGEP, CSHOs should be careful to reference in the citation's alleged violation
description only RAGAGEP that are actually applicable to the equipment and process being
inspected. CSHOs have sometimes referenced inapplicable API relief valve RAGAGEP in
citations involving ammonia refrigeration processes.
(1) PSM preamble accessed
at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=PREAMBLES&p_id=1
041 on January 15, 2013.