This month marks the 20th anniversary of OSHA’s Process Safety Management standard, which is built upon Recognized and Generally Accepted Engineering Practices (RAGAGEP). There was no way OSHA could write a “specific” standard to cover all the types of processes handling the list of Highly Hazardous Chemicals (HHC) so they instead wrote what is called a “performance oriented standard” that is VERY OPEN and flexible so that an employer can best decided how to run their process safely. The intention was that the employer would adopt published RAGAGEPs to design, build, operate and maintain their highly hazardous process.
In 1992, participation on the committees that wrote and approve many of these lonstanding RAGAGEPs was a select few who were truly focused on sound engineering practices for their particular RAGAGEP with the fundamental principle that safety would continuously be improved. Most of the well established RAGAGEPs (e.g. NFPA, ASME, API, ANSI, etc.) that were in place before PSM and are used by multiple industries have remained true to their mission; however, some industries have learned how to “influence” RAGAGEPs and eventually result in their sometimes questionable revision. And this is the question I pose… have some RAGAGEP become dilluted with “industry interest” over the interest in people and process safety?
Let’s examine the term “Recognized and Generally Accepted Good Engineering Practice”. Just by the words used, one would expect all codes/standards that call themselves RAGAGEP to be heavily influenced, if not solely influenced, by true engineers who are formally educated, have many years of experience in applying engineering principles in real-life applications, and have the specialized skill set to the particular type of engineering being discussed/debated in the code/standard. Most of the credible approving bodies for these codes and standards require a diverse make-up of these committees between the “producer”, the “user”, and those with a “general interest”. Notice that there is NO REQUIREMENT for the make-up of these three categories in relation to their technical skills regarding the topic of the code/standard. ANSI actually requires that no category of these three can make up more than 1/3 of the total committee when the topic of the code/standard is related to safety (i.e. Section 2.3 of ANSI Essential Requirements: Due process requirements for American National Standards). So again, one would think that the “deck could not be stacked” in anyone’s favor between the three supposedly “independent” categories of committee members and since this is an “good engineering practice” that it is formulated by engineers, debated by engineers, and voted upon by engineers????
Some trade groups have published guidelines for decades for their members; however, when PSM came on the scene, these guidelines were quickly pointed to and actually referenced by OSHA as being an example of a RAGAGEP. I believe the trade groups were a bit taken back by this reference as I do not think they ever thought (before PSM) their “guidelines” would be scrutinized by regualtory agencies or worse yet that a company would implement their “suggestions” as part of compliance with an OSHA/EPA standard.
So there has been a rush over the past 10 years or so (no joke – 10 years is a rush for an industry to agree to codes/standards) to better clarify practices and expectations. Some of these groups hoped that merely changing the name of their publication(s) would solve the problem and reduce the confusion about how their publication should be used. Some groups on the other hand are making major efforts to revise their publications and here lies the concern of this safety professional.
Before PSM, people sat on these committees and commented and debated about what they thought were “best practices”, above and beyond OSHA standards that may have existed; keeping in mind that OSHA standards are the BARE MINIMUM and often time not nearly as protective as many employers wish to achieve. Some of these committees never thought that their publication would become a REQUIREMENT one day. So these RAGAGEPs were based on best practices already in place by many facilities and the code/guideline was an effort to formalize these practices for those who wanted to implement them at their facility. PSM comes into the picture and directly references these codes and some industries go into panic mode as now these “best practices” (as they were referred to before PSM) have become an expectation and “ENFORCEABLE” by regulatory authorities. So now we have two groups in panic mode… an industry(s) and their trade group(s)!
PSM/RMP, in my opinion, has done more for safety as a whole in the chemical industry than anything over the past 20 years. I had the great opportunity to work for companies that actually EMBRACED PSM and spent millions to just educate people like me on what “process safety” really is and how it is to be developed, implemented and managed on a DAILY BASIS. Many trade groups took the opportunity to broaden their “guidelines” and to actually make them more stringent and straight forward so as to eliminate confusion on what exactly needed to be done or how it was to be done. In some cases, the RAGAGEP was more prescriptive than the OSHA standard(s) related to the hazard. But it concerns me when I see a significant shift in the makeup and size of these standards committees, as well as their output! Did you know that in recent years some trade groups changed their by-laws to allow a different make-up of their committees; sometimes going from 10-12 highly qualified engineers to up to 20 members with very little credentials to add value to the technical code/standard. This was all done behind the mask of “industry participation increases the value of our codes and standards”. I view this as the trade group had an angry membership and their survival was based on their members paying dues. So they open their committees up to anyone who is a member, regardless of qualifications or potential “conflicts of interest”. The result sometimes is downright scary! These committees are often driven by “consensus voting” of the committee members, which is a common requirement of the approving bodies of these codes and standards; so if “an industry” can garner enough support to change a practice that was instituted by the 10-12 qualified engineers many years ago, they can change a code/standard merely by “stacking the deck” with members who find certain requirements burdensome. Some would say, yes – but don’t nearly all of the approving bodies require the code/standard to be commented on by the public? Yes, to my knowledge all the credible approving bodies require a “public comment period”; however, the public can say what it wants, the end result lies with the “voting committee”!
I often times get e-mails and phone calls telling me I need to get more involved with these committees rather than fighting the process. I personally do not believe I am qualified to sit on a real RAGAGEP committee, as I am not a degreed engineer with the education, skill set, or engineering experience needed to make a practical contribution to such a code or standard – heck I have a hard enough time reading them and implementing them! I welcome revisions to codes and standards, as times have changed drastically over the past 20-30 years, but the laws of physics and sound engineering practices have NOT. What was a good practice 20 years ago in relation to process safety, about 95% would still apply today. Maybe a new Non-Destructive Testing (NDT) method comes along and can actually make testing easier, cheaper, and more accurate. Or maybe an industry, as a whole, has enough data to support the removal of a strenuous requirement based on the other more recently implemented layers of protection in their process design; but these revisions need to stay within SOUND ENGINEERING practices that have been discussed and analyzed by qualified engineers who can show that sound engineering practices were the driving force and not become a mere consensus vote from members of a trade group, who may or may not have the education, skill set, or engineering experience needed .
So I come back full circle to my question, have we diluted some RAGAGEPS because of PSM? It is my opinion that YES, some so called RAGAGEPs are being watered down merely to place roadblocks in front of safety inspectors and to lessen the “burdens” on membership, rather than trying to strength the safety of an industry. It is sad that after 20 years of such enormous advancements in process safety that I can sit here and write this and have so many process safety enthusiasts from multiple industries shaking their head in agreement. There are some of us that are true to safety, even when the fight gets ugly. But could it be possible that there are some wolves in sheep clothing spouting their rhetoric under the cover of safety, all the while making changes to once sound practices merely to appease their dues paying membership? Let’s hope not, but I am becoming more doubtful with each passing year!