For process safety engineers and safety practitioners, understanding the differences between Recognised and Generally Accepted Good Engineering Practices (RAGAGEP) and the As Low As Reasonably Practicable (ALARP) principle is not just a theoretical exercise - it is an operational necessity.
11.02.2025
These two regulatory approaches shape how safety decisions are made, enforced, and justified in the United States and the United Kingdom. For professionals working in multinational industries such as oil and gas, petrochemicals, pharmaceuticals, and heavy manufacturing, failure to grasp these distinctions can lead to compliance failures, project delays, and even legal consequences.
For those involved in US-owned or operated projects in the UK, the challenge is even more pronounced. Many American companies operating in Britain apply US safety principles by default, potentially clashing with the UK’s risk-based regulatory environment. Safety practitioners must therefore bridge the gap between these regulatory frameworks, ensuring compliance with UK law while also satisfying the expectations of US-based corporate leadership and regulators.
At their core, both RAGAGEP and ALARP aim to reduce risk and prevent major accidents, but they do so through very different mechanisms.
RAGAGEP: A Standards-Based Approach (US)
In the United States, process safety regulation is highly prescriptive, meaning companies are expected to follow specific engineering codes and standards. OSHA’s Process Safety Management (PSM) regulation (29 CFR 1910.119) requires that process safety systems comply with RAGAGEP, which refers to engineering, operating, or maintenance practices that are widely recognised as safe within an industry.
“The employer shall document that equipment complies with recognised and generally accepted good engineering practices.”
OSHA Process Safety Management Standard (29 CFR 1910.119)
The American Society of Mechanical Engineers (ASME), the American Petroleum Institute (API), and the National Fire Protection Association (NFPA) are among the leading organisations defining RAGAGEP for different industrial applications. These standards dictate the design, inspection, and maintenance requirements for critical systems such as pressure vessels, piping, electrical systems, and fire protection measures.
From a safety practitioner’s perspective, RAGAGEP is clear-cut: implement the requirements set out in the standard, and compliance is achieved. If a company chooses not to follow an established standard, it must provide a robust engineering justification proving that its alternative approach offers an equal or greater level of safety.
The UK, in contrast, follows a goal-setting regulatory framework. Under the Health and Safety at Work etc. Act 1974, the emphasis is on reducing risk as far as reasonably practicable (ALARP). Rather than mandating adherence to specific engineering codes, UK law requires businesses to assess whether further risk reduction measures are justified based on a cost-benefit analysis.
This places the burden on duty-holders to demonstrate that they have taken all proportionate steps to manage risk, rather than simply complying with a predetermined checklist. The Health and Safety Executive (HSE) considers compliance with British and international standards (e.g., BS EN, ISO, IEC) as strong evidence that risks have been reduced ALARP, but these standards are not mandatory in the way that RAGAGEP is in the US.
For safety professionals, ALARP demands a more nuanced approach. Rather than simply ensuring compliance with a set standard, practitioners must evaluate hazards on a case-by-case basis and justify why certain measures were or were not implemented.
For process safety engineers working on US-owned or operated projects in the UK, understanding these regulatory differences is essential. A failure to properly navigate these two systems can lead to conflicts between corporate expectations and UK regulatory requirements, as well as inefficiencies in project planning and execution.
One of the most common challenges arises when US-based companies apply RAGAGEP thinking in UK projects, assuming that adhering to API, ASME, or NFPA standards is sufficient for compliance.
However, UK regulators do not automatically accept compliance with US standards as meeting ALARP requirements. The Buncefield oil depot explosion (2005) demonstrated this distinction clearly. Investigators did not focus on whether the site complied with a specific standard, but whether operators had done everything reasonably practicable to prevent an overfill event.
A process safety engineer working on a US-owned refinery in the UK, for example, may encounter a situation where the American parent company (or its insurer’s) insists on installing an NFPA-compliant fire protection system, but HSE may require additional risk assessments to demonstrate why that system represents the lowest reasonably practicable level of risk.
Failing to recognise this difference can lead to delays in regulatory approvals, costly design modifications, or even legal action if an incident occurs and UK authorities determine that risk reduction efforts were insufficient.
RAGAGEP and ALARP also fundamentally differ in how they approach cost. In the RAGAGEP framework, cost is rarely a factor—if a recognised standard exists, it must be followed, regardless of expense. In contrast, ALARP explicitly considers the proportionality of cost to risk reduction.
For safety practitioners in budget-sensitive industries, this can be a crucial distinction. If a US-based owner demands compliance with API 570 for piping inspection, UK-based engineers may need to challenge whether an alternative, equally effective approach could be justified under ALARP, potentially saving significant costs while still maintaining compliance with UK law.
Another critical difference lies in how risk reduction measures are justified. In RAGAGEP, a process safety engineer can point to a specific section of an ASME or NFPA standard and demonstrate compliance. In ALARP, justification requires a broader assessment of hazard likelihood, severity, and cost-effectiveness of mitigation strategies.
For example, consider an engineer working on a US-owned chemical plant in the UK, where corporate leadership insists on following US electrical classification standards (NFPA 70E) for hazardous areas. UK regulations may require a more tailored assessment under DSEAR (Dangerous Substances and Explosive Atmospheres Regulations 2002), requiring the engineer to demonstrate that the NFPA approach is not just compliant, but that it represents the lowest reasonably practicable level of risk.
Without an understanding of these differences, engineers may misinterpret what is required for compliance, either over-engineering solutions to meet unnecessary standards or underestimating what UK regulators expect.
Process safety engineers and safety practitioners must act as translators between these two regulatory worlds, ensuring that projects remain compliant while avoiding unnecessary costs or project delays. This requires:
For process safety professionals working across borders, the ability to navigate these regulatory differences is not just a compliance issue—it is an essential skill that can influence project success, financial efficiency, and most importantly, workplace safety. Understanding the interplay between RAGAGEP and ALARP allows engineers to design safer, more practical, and legally compliant solutions, ensuring that multinational projects operate smoothly within their regulatory environments.
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