In March, 2007, the CSB recommended that the American Petroleum Institute1(API) and the United Steelworkers International Union2 (USW) jointly lead the development of an ANSI consensus standard with guidelines for fatigue prevention. The recommendation arose from the investigation of the BP Texas City refinery incident in 2005 (CLICK HERE for additional information on that accident). Their work resulted in the Recommended Practice ANSI/RPI 755, Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical Industries, First Edition, April 2010. The CSB is now requesting public comment on the draft evaluation of the actions taken by the API and USW to implement the CSB recommendation; however, the CSB has issues with the process in which the RP was developed and some aspects of the document. This evaluation offers the staff’s critique of two documents that were prepared in response to the recommendation, as follows:
- Recommended Practice ANSI/RPI 755, Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical Industries, First Edition, April 2010, developed under the auspices of API serving as the ANSI secretariat or convener; and,
- API Technical Report 755-1. Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical Industries, Scientific and Technical Guide to RP-755, 2010. Prepared for the American Petroleum Institute by Circadian®.
To obtain copies of these documents, interested parties should contact the American Petroleum Institute via internet, by phone (1-800-854-7179 or 303-307-7956) or fax (303-397-2740). Interested parties in the public and private sector are invited to comment publicly on:
- Any aspect of the draft CSB analysis summarized in this document;
- Whether RP 755 is consistent with the CSB recommendation that triggered it; and,
- Any other relevant aspects related to RP 755 and the management of fatigue risk in the refinery and petrochemical industries.
Written comments must be received by the CSB on or before April 12, 2013, at 5 p.m. EDT. Following the public comment period, a CSB public meeting to consider the issue will occur at 9:30 a.m. EDT on April 24, 2013, in Washington, DC. The meeting will be held at the Ronald Reagan Building and International Trade Center, Horizon Room, 1300 Pennsylvania Avenue N.W., Washington, DC 20004. Electronic submission of comments is highly preferred. Comments should be submitted by email to [email protected]. They may also be submitted by mail to Chemical Safety and Hazard Investigation Board, Office of Congressional, Public, and Board Affairs, Attn: D. Horowitz, 2175 K Street, NW, Suite 650, Washington, DC 20037.
Issues that the CSB Staffer’s have with the current version:
- The document was not the result of an effective consensus process, and therefore does not constitute a tool that multiple stakeholders in the industry can “own.” It was not balanced in terms of stakeholder interests and perspectives, and did not sufficiently incorporate or take into account the input of experts from other industry sectors that have addressed fatigue risks.
- The document lacks explicit requirements in the form of “shall” language for the essential elements of an effective fatigue management system.
- The document places undue emphasis on “soft” or “personal” components of fatigue control, such as self-evaluation by employees, evaluation by supervisors, and training and education, without supporting scientific evidence of their efficacy.
- Although the RP requires limits on hours and days at work, the limits are generally more permissive, and therefore less protective, than those suggested by current scientific knowledge. The permissive limits are based on an unproven assumption that implementation of a particular FRMS will “compensate” for the risk from excessive hours and days at work.
CLICK HERE (pdf) to download the detail explanation of each of these concerns.