OSHA's MI standard requires inspections and tests of process equipment at frequencies consistent with applicable manufacturer's recommendations and good engineering practice, or more frequently if experience indicates it. OSHA does not specify inspection intervals for specific equipment types but defers to RAGAGEP, which stands for Recognized and Generally Accepted Good Engineering Practices. These letters address which standards constitute RAGAGEP, how to handle equipment where manufacturer's recommendations no longer exist, and whether risk-based inspection approaches satisfy the standard.
What OSHA Has Said
May 11, 2016
Risk-Based Inspection as an Acceptable MI Frequency Methodology
OSHA addresses whether a risk-based inspection (RBI) program satisfies the MI inspection frequency requirement. OSHA position: RBI is acceptable if it is based on recognized methodology such as API 580 or 581 and is systematically documented.
Read OSHA Letter ↗
May 11, 2016
RAGAGEP and Inspection Frequency and Specific Standards Referenced
OSHA addresses which industry standards constitute RAGAGEP for various equipment types including API 510, 570, 653, and ASME codes. Facilities must identify the applicable RAGAGEP for each equipment category and document compliance.
Read OSHA Letter ↗
Sep 16, 1996
Equipment-Specific Inspection Intervals When Manufacturer Data Is Unavailable
OSHA addresses the situation where original manufacturer inspection recommendations are unavailable. OSHA expects the employer to use applicable industry standards and the facility's own inspection history to establish appropriate intervals, not to defer inspection indefinitely.
Read OSHA Letter ↗
⚡ Key Compliance Takeaway
Know your RAGAGEP by equipment type. If you use RBI, ensure the methodology is documented and based on a recognized standard. When manufacturer data is unavailable, industry codes such as API 510, 570, and 653, along with your own inspection history, define the interval.