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OSHA Issues Revised RAGAGEP Enforcement Guidance Memorandum

Prepared for the Katten Safety Advisory Group
Advisory | May 18, 2016

Last week, the Occupational Safety and Health Administration ("OSHA") published a revised version of its guidance memorandum, "RAGAGEP in Process Safety Management Enforcement" (the "RAGAGEP Memorandum"). The original version of the RAGAGEP Memorandum was published on June 5, 2015. See KSAG Alert 2015-25. As we have discussed, the RAGAGEP Memorandum represented an unprecedented expansion of OSHA's interpretation of the term recognized and generally accepted good engineering practices ("RAGAGEP") under the agency's process safety management ("PSM") standard. According to media reports, OSHA agreed to the revisions as a part of a settlement to resolve industry challenges to the validity of the ....

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