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OSHA Issues RAGAGEP Enforcement Guidance Memorandum

Prepared for the Katten Safety Advisory Group
Advisory | June 10, 2015

Yesterday, the Occupational Safety and Health Administration ("OSHA") issued an enforcement memorandum entitled "RAGAGEP in Process Safety Management Enforcement." As we discussed at the recent KSAG quarterly meeting, OSHA's experience enforcing the Recognized and Generally Accepted Good Engineering Practices ("RAGAGEP") provisions in the Process Safety Management ("PSM") standard have led the agency to conclude that it needs to provide additional clarity on the meaning and use of this term, and also to provide detailed guidance to inspectors issuing RAGAGEP citations...

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