Here is some interesting info concerning the OSHA citations that BP did not document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP).

In addition most of the citations are concerned with inlet line pressure drop on numerous pressure reliefs did not comply with recognized and generally accepted good engineering practices (RAGAGEP), such as API Recommended Practice 520

API RP 520's recommended guideline of 3% inlet pressure loss is not RAGAGEP for existing relief valve installations

RAGAGEP is not a standard or code; it is a benchmark against which performance can be judged.There is no mandatory code that governs relief valve inlet pressure loss.

OSHA believes there is a mandatory standard in the refining industry that prohibits inlet pressure loss exceeding 3% on existing relief valve installations. That is not legally or factually correct; there is no such legal obligation and it is not common refining industry practice to apply 3% to existing relief valves.

Most refiners in the United States allow inlet pressure losses on existing relief valve installations in excess of 3% and up to 5%.

OSHA is now requiring that BP must modify its relief systems beyond applicable industry standards.

It appears that the terms of the 2005 Settlement of Agreement (SOA) have changed with the new administration and OSHA leadership of a new sheriff in town.

There is no amount of money that will bring those workers who perished back. Yet at the same time there needs to be equitable balance in all this. Unfortunately, an opinion that OSHA and many do not agree on.

— By John Astad on Nov. 3 at 10:28 AM