PSM and RMP Citations/Analysis

NOTICE:  The OSHA cases found in these posts may be taken from OSHA citations BEFORE the “informal conference” takes places.  These cases are posted for AWARENESS and EDUCATIONAL purposes only.  I have scrubbed company names and locations from my postings, but not from the OSHA and EPA documents.  These posts are in NO WAY meant to shame any company, just providing information showing the things OSHA/EPA are finding in their PSM/RMP inspections.

EPA RMP citations @ agricultural products facility (NH3 & $119K)

Respondent is the owner and operator of a facility that stores, manufactures, and distributes agricultural products, including anhydrous ammonia. The threshold quantity for anhydrous ammonia, as listed in 40 C.F.R. § 68.130, is 10,000 pounds. On or about August 22-23, 2023, a representative of the EPA conducted an inspection of the Respondent’s Facility to determine…...

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EPA RMP citations @ aerosol can manufacturing facility (Flammable Gases & $154K)

The respondent owns and operates a single-site aerosol can manufacturing facility that uses, stores, and handles Isobutane (CAS# 85-28-5), a regulated substance, at the Facility in amounts over the threshold quantity for Isobutane of 10,000 lbs. The facility used, stored, and handled Butane (CAS# 106-97-8), a regulated substance, at the Facility in amounts over the…...

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EPA RMP GDC @ food facility (NH3 & $119K w/ $300K SEP)

Respondent was the “owner or operator” of the Facility. The Facility’s refrigeration system used approximately 5,913 pounds of anhydrous ammonia. Accordingly, at the time of the violations alleged herein, Respondent operated a stationary source that handled and stored anhydrous ammonia, listed at 40 C.F.R. § 68.130, and thus was subject to the General Duty Clause…...

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EPA RMP citations @ metal alkyl manufacturing facility (Toxics & $125K)

Respondent is the owner and operator of a facility where EPA inspected from May 17 to May 19, 2022, to determine Respondent’s compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68 (“the Inspection”).  The Respondent’s facility is a metal alkyl manufacturing facility.  The facility produces a variety of highly reactive metal alkyls…...

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EPA RMP/EPCRA citations @ food facility (NH3 & $178K)

Respondent owns or operates the AMPI production facility that uses anhydrous ammonia in its refrigeration processes. From December 20, 2021, to May 17, 2022, EPA conducted an offsite compliance monitoring investigation of the Facility. During that investigation, the EPA representatives identified alleged violations of section 112(r)(1) of the CAA and section 312 of the EPCRA…....

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EPA RMP citations @ food ingredients facility (NH3, H2 & $207K w/ $122K SEP)

Respondent is the owner and operator of a facility that has more than 10,000 pounds of anhydrous ammonia and Hydrogen in processes. Information gathered during the EPA inspection revealed that Respondent uses anhydrous ammonia in the production of food ingredients and produces and stores hydrogen, and therefore, is engaged in a process at its facility…....

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EPA RMP/EPCRA citations @ food facility (NH3 & $25K w/ $90K SEP)

This case is interesting, as I have always challenged the concept that an engine room (membership required)with large roll-up utility doors and windows and personnel/fire doors that are found propped open more often than not would contain the “catastrophic release of NH3”.  It seems this EPA inspector was one who attended one of my 5-Day…...

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EPA RMP/EPCRA citations @ food facility (NH3 & $25K w/ $90K SEP) Read More »

EPA RMP/EPCRA citations @ food facility (NH3 & $25K w/ $90K SEP)

This case is interesting, as I have always challenged the concept that an engine room (membership required)with large roll-up utility doors and windows and personnel/fire doors that are found propped open more often than not would contain the “catastrophic release of NH3”.  It seems this EPA inspector was one who attended one of my 5-Day…...

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EPA RMP citations @ ice cream plant (NH3 & $93K)

This EPA CAFO has me wondering who upset the U.S. EPA. There are only two (2) violations; one is the most cited RMP violation in the past seven years and is quite minor; the other was one of the newest RMP requirements, and those two violations netted a $93,000 citation. Respondent is the owner and…...

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EPA RMP citations @ bleach manufacturing plant (Cl2 & $88K)

The Respondent owns and operates a bleach manufacturing facility, which operates a bleach manufacturing process (the Process) and maintains a maximum chlorine inventory greater than the threshold quantity of 2,500 pounds. The Process is subject to OSHA’s process safety management standard, 29 C.F.R. § 1910.119, because the Process involves greater than the threshold quantity of…...

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EPA RMP GDC citations @ bulk storage facility (Flammable Liquids & $23K w/ $150K SEP)

Respondent is the owner and operator of a facility. Respondent operates a bulk liquid storage facility and offers a full range of heating, blending, and product services. Various products, such as vegetable oil, chemicals, and petroleum products, are received in tanks for storage and transferred out of the facility to customers. Some of the petroleum…...

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EPA RMP citations @ chicken processing plant (NH3 & $10K w/ $37K SEP)

This case reflects a common issue in ammonia refrigeration: Lack of or Poor Lockout/Tagout Practices. This 1,600-pound release was caused by an existing ammonia compressor that was started up on an ammonia line that was meant to be “TAGGED OUT” of service (however, the tag had fallen off) while in the process of tying the…...

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