I am Grandfathered
Since the advent of government enforcement many have probably said / defended / or heard that they are grandfathered in. No different when it comes to PSM RMP implementation and of that the best practices we know as RAGAGEP. When some says their grandfathered to a particular standard, we like to say show me the letter from the agencies that have the ability to give you citations.
IIAR has been in the works the last year to develop IIAR 9, which will be a standard on RAGAGEP for facilities built before a standard / bulletin/ guideline was produced by IIAR and what they should do to adopt best practices. If you are a PSM professional, your PSI, PHA, MI, and MOC are all elements with chances to make sure that your program could evaluate, incorporate, and even implement newer practices.
GCAP hopes that IIAR takes the opportunity to also address in the standard the idea of being grandfathered to a previous edition of a particular standard / bulletin / guideline. If you have had GCAP’s PSM/RMP class or read the book, you could see how valuable a particular RAGAGEP Gap Analysis/Audit would be beneficial to improving the program and evaluate the deficiencies from out dated practices no longer supported by the publishing group.
It will be of particular interest to see if the regulatory arena agrees with what IIAR will have to say about adopting new standards for older processes. Here is what OSHA’s has already published on this supported with shalls of 1910.119:
“Older covered equipment may not have been designed and constructed under an applicable RAGAGEP because none existed at the time of design and construction. Alternatively, the equipment may have been designed and constructed under provisions of codes, standards, or practices that are no longer in general use. In such cases, 29 CFR 1910.119(d)(3)(iii) requires employers to determine and document that the equipment is designed, maintained, inspected, tested, and operating in a safe manner. Failure to do so may be cited under 1910.119(d)(3)(iii).
When writing 1910.119(d)(3)(iii) citations, always cite the employer for failing to determine and document that the relevant equipment is designed, maintained, inspected, tested, and operating in a safe manner.
If the employer has adopted an appropriate internal standard applicable to such older equipment, 29 CFR 1910.119(d)(3)(ii) requires the employer to document that the equipment complies with the internal standard. Failure to do so may result in a citation under 29 CFR 1910.119(d)(3)(ii)” all this can be found on OSHA’s website