Early last year I wrote about some trade organizations that were “revising” their codes/practices, which in turn were making them “more flexible”. I stated it then and I will state it again, this time along with the US Chemical Safety Board… this is a REALLY BAD idea. Both OSHA and EPA wrote “performance oriented” standards for process safety. This allows the employer/owner/operator to choose the best suited Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs) to design, build, operate, and maintain their “covered processes”. OSHA and EPA have issued citations against these RAGAGEPs, as, in many cases, the employer/owner/operator were not doing what these codes/practices called for. So this apparently has angered “paying members” to these trade groups, which is resulting in the “dumbing down” of these codes/practices. Take for example…