Farley to Address AFPM Conference on Inspection RAGAGEP and Retro-PMI

February 1, 2022

Partner Mark L. Farley will address the AFPM 2022 National Occupational & Process Safety Conference & Exhibition in San Antonio, Texas on May 11 – 12, 2022. Farley’s presentation -- Inspection RAGAGEP and Retro-PMI: The Government's Evolving View – will discuss the regulatory requirements for mechanical integrity inspections.

Farley serves as incident response counsel to some of the largest refiners and chemical manufacturers in the United States. He also defends companies against allegations by U.S. EPA and federal Occupational Safety and Health Administration in the context of post-incident enforcement.

High profile incidents in the process industries have driven a renewed focus on the issue of positive material identification on previously installed components, including piping that may have been installed decades before the incident. According to Farley, companies now confront evolving and aggressive interpretation of these requirements by enforcement agencies: “Increasingly, the agencies discount the performance-oriented nature of the regulations and instead attempt to apply RAGAGEP and other industry standards as highly prescriptive requirements.”

The presentation will discuss the regulatory basis for retro-PMI and the evolution of inspection RAGAGEP and 100 percent component inspections. Farley also will consider relevant enforcement interpretations in the context of major incidents involving accelerated corrosion resulting from unanticipated / unknown material composition.

The AFPM National Occupational and Process Safety Conference (NSC) features a variety of safety practices, programs, and roundtable discussions to improve safety performance at refineries and petrochemical facilities.

Farley & Partners LLP is a Chambers-ranked boutique law firm in Houston, Texas with a nationally recognized workplace safety and crisis management practice. The 2021 Chambers USA Guide describes the firm as a “go-to for major government investigations and catastrophic incidents in the U.S.”