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: