Equipment Deficiencies and Safe Operation — OSHA Letters of Interpretation

OSHA's RAGAGEP enforcement memo tells inspectors that MI equipment outside acceptable limits, as defined by the process safety information (including RAGAGEP), is deficient under (j)(5). The employer must correct it before further use, or in a safe and timely manner when necessary means are taken to assure safe operation in the interim. Failing to do either can be cited. Where an employer keeps running deficient equipment on interim safeguards pending repair, it must use its management of change procedure for that continued operation when (l) requires it.

In a letter to a U.S. Senator about refinery structures exposed to explosion hazards, OSHA said blast-resistant structures must be designed and maintained to RAGAGEP. Deficiencies found in a facility siting evaluation must be resolved and documented under (e)(5), and changes to structures go through MOC. Where a structure contains equipment covered by mechanical integrity, MI applies: new equipment must be fabricated to be suitable for its application under (j)(6)(i), and checks and inspections must confirm it is installed properly and consistent with design specifications and manufacturer's instructions under (j)(6)(ii).

A manufacturer with frequent routine and external visual inspections asked how much paperwork (j)(4)(iv) requires. OSHA said recording only conditions needing attention is acceptable if the procedure makes clear that no finding means a satisfactory result, records may be organized by process unit and kept electronically if readily retrievable, and inspection records must be kept for the life of the process. OSHA noted that both good and bad results are used to set inspection and test frequencies based on operating experience.