In part 1 of this series, we discussed what is RAGAGEP and how they are/were developed. In fact, this knowledge will help us to understand a few pitfalls in some of the RAGAGEPs, and why it is important to get the correct knowledge and experience within these codes and standard groups to further enhance the desired goal of improved process safety. We have conducted well over 400 NEP (National Emphasis Program) type PSM inspections in the last 10 years. We track findings in general for each inspection to find common issues to better improve our clients' PSM programs and process safety performance. A common practice, as it pertains to RAGAGEP, is for facilities to have a “RAGAGEP List.” There is nothing wrong with the list itself if it is used by engineering to ensure equipment in the process is manufactured and maintained to those standards, and that there is a connection to the RAGAGEP from the list to a component in the process. For example, a common RAGAGEP for all industries is Section VIII of the ASME Boiler and Pressure Vessel Code (BPVC). This code relates to most pressure vessels and documentation for a vessel, regardless of it being registered with the NB or not, would include a form U1A. The U1A will show the RAGAGEP (code) used to construct the vessel, material of construction, vessel size, number of nozzles/connections, joint efficiency, and a host of other information. The U1A by itself meets all the requirements set forth in the PSI section of the PSM regulation. There is no need for a list of RAGAGEPs, since the required information is with the equipment specification itself, and there is no question as to the code and standard used. On the other hand, if no U1A is available, then it will be up to the user/owner to document what code and standard or RAGAGEP was used to construct the vessel. The list of RAGAGEP does not satisfy that requirement nor does a list of material of construction. Every piece of equipment, instrument, pipe segment, or device shown on the P&ID or part of the covered process is designed to some code or standard, but that code or standard may not be considered RAGAGEP. As an example, Joe’s Refinery built all the components in the refinery to “Joe’s” code and standard, but Joe’s codes and standards do not meet or exceed Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) such as American Petroleum Institutes (API’s) requirements. If they did meet or exceed API’s requirements, Joe’s code and standard would be fine to use.
It is important that each component in your process include within the specification information the design code and standard used, the material of construction is identified, and that the code and standard is recognized and generally accepted.