With all of the regulations that companies in specific industries have to comply with, it is no wonder there are so many incidents of non-compliance and fines distributed by regulators. In addition to the written law, there are also best practices that OSHA endorses and fines for as well. I am specifically talking about RAGAGEP, which was first introduced in OSHA’s Process Safety Management (PSM) standard, CFR 1910.119. RAGAGEP stands for Recognized and Generally Accepted Good Engineering Practices.

The problem with RAGAGEP is that it is up to the owner/operator to understand and incorporate these practices. OSHA does not define them yet, but there are still citations for not complying with RAGAGEP. It seems complicated enough to try to accomplish compliance with the written standards considering all of the grey areas of the law, but organizations are held to an even higher standard of complying with best practices that are accepted but not written into the law. From the little I know about RAGAGEP, it seems that it is helping to hold the industry to a higher standard, so I am supportive of it, but how are companies supposed to stay up to date on what is OSHA accepted best practices?