We have discussed this before; there is a significant difference between Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) and OSHA’s minimum performance compliance standards. OSHA standards may be adequate when quantities of the hazardous material(s) are managed at a lower inventory level; however, once those inventory levels exceed the PSM/RMP threshold, the old minimum standards are NOT adequate for those of us trying to design safety systems for these processes. We can use 1910.106 as our example again.