By Brent I. Clark and Craig B. Simonsen

PSM Blog PicOSHA has just published a Standard Interpretation (Interpretation) to provide guidance on the enforcement of the Process Safety Management (PSM) Standard’s “recognized and generally accepted good engineering practices” (RAGAGEP) requirements, including how to interpret “shall” and “should”  language in published codes, standards, published technical reports, recommended practices, and similar documents.

According to
Continue Reading OSHA Interpretation on Recognized and Generally Accepted Good Engineering Practices in Process Safety Management

By Andrew H. Perellis, Philip L. Comella, and Craig B. Simonsen

The U.S. Environmental Protection Agency has recently released its “Revised Policy on Managing the Duration of Remedial Design/Remedial Action Negotiations” (Revised Policy). The Revised Policy contains the Office of Site Remediation Enforcement’s (OSRE) procedures for reducing the duration of remedial design/remedial action (RD/RA) negotiations. The stated
Continue Reading Revised Policy on Managing the Duration of Superfund Negotiations