Have you ever read a RAGAGEP and wished you had been a fly on the wall in the room where a particular requirement was presented and debated amongst the committee members? I have set on my fair share of RAGAGEP committees over the past 20 years and in almost all of muy experiences, when someone would bring an idea to the floor that was well outside any fundamental risks acceptance or engineering, they were usually asked to sit down in a polite manner. Today, sometimes I wonder what goes on behind the closed doors.
As I have said, the “dumbing down” of some of the most prestigious RAGAGEPs that have been around for decades (well before OSHA promulgated its PSM standard) continues to increase. This is done simply to limit OSHA and EPA’s enforcement – NOT because of new technology or better science/engineering. Here is one that left me scratching my bald head until it bled…