As we continue to “dumb down” RAGAGEPs to take away OSHA/EPA’s ability to cite fundamental engineering failures found in processes handling HHC/EHS, the issue of “conflicting requirements” continues to be troubling. As my Anhydrous Ammonia clients learned firsthand last year, with the 7th edition of CGA 2.1, the RAGAGEP has some NEW requirements for pressure testing and leak testing piping. Although this was a revision, it was IN NO WAY necessary, and there is just a tiny (all pun intended) exception that conflicts with the pressure/leak testing requirements found in ASME B31.3 and 31.5.
Call me a pessimist, but I believe this revision was added to make the last sentence “allowable” rather than simply referencing the RAGAGEPs the standard already references (B31.3 and 31.5). They wanted to sneak in these ten (10) little words, which is a clear VIOLATION of ASME B31.3, 345.4.1, and 345.5.3.
The new content that CGA 2.1 now allows (conflicting with ASME B31.3/B31.5)…
(emphasis by me)