The meaning of “should”

When implementing the performance‐based Process Safety Management (PSM) Standard (OSHA 1910.119), industry needs to comply with applicable recognized and generally accepted good engineering practices (RAGAGEP) for their facility. While this may seem like a simple task, determining what is applicable and how it affects the design, construction, inspection/testing, and operations, it can be a significant effort. This paper aims to provide guidance on interpreting the “should” versus “shall” debate, particularly how to deal with “should” provisions, why this matters, and share lessons learned from AcuTech's extensive onsite observations where the impacts of these interpretations are seen in process safety programs.