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 & EPCRA Citations @ Food Plant (NH3 & $210K

Respondent operated a facility that utilizes anhydrous ammonia to provide cooling capabilities to processing, shipping, cooler areas, silos, and chillers for its beef and meat products. On March 30, 2022, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, EPCRA Sections 304-312,…...

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OSHA PSM Citations @ Food Processor (NH3 & 131K)

The state of VA has fined a food processor $131,535 for a July 31, 2024 anhydrous ammonia leak that hospitalized 33 people. The leak triggered the evacuation of 287 employees working at the facility. Five of the 33 victims were hospitalized with serious conditions, 17 had serious but non-life-threatening conditions, and 11 had minor symptoms…....

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EPA RMP Citations @ Food Facility (NH3 & $152K)

Respondent operated a facility (the “Facility”) to process, store, and distribute prepackaged salads, fresh-cut vegetables, and other food products. At all times relevant to this CAFO, Respondent produced, used or stored more than 10,000 pounds of ammonia (anhydrous) at the Facility and was subject to the requirements of CAA § 112(r)(7). At all times relevant…...

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EPA RMP citations @ Agriculture Supply business (NH3 & $33K)

Respondent owns and operates a facility that wholesales animal feeds, fertilizers, agricultural chemicals, pesticides, seeds, and farm supplies, including agricultural anhydrous ammonia. On or about August 9, 2023, EPA inspected the Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that…...

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EPA RMP citations @ water treatment plant (Cl2 & $13,500)

This is what drives me crazy! A water treatment plant that falls under EPA’s RMP and yet has made zero effort to comply with the standard gets 11 citations, and the fine was $13,500, which was “adjusted” down to $10,800. This is a PUBLIC entity handling Chlorine (Cl2) in a densely populated area (see Google…...

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EPA RMP GDC & EPCRA citations @ cheese manufacturing facility (NH3 & $178K)

The respondent was the owner or operator of the cheese production facility that used anhydrous ammonia in its refrigeration processes. Respondent was required to have a material safety data sheet for anhydrous ammonia under the Occupational Safety and Health Act of 1970, 29 U.S.C. § 651 et seq. , and its associated regulations. Respondent produced,…...

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6,000 pound NH3 release leads to $169K EPCRA/CERCLA citations

The respondent was an owner or operator of the ice manufacturing facility where anhydrous ammonia is used in the manufacturing of ice. Anhydrous ammonia, CAS #7664-41-7, has a reportable quantity of 100 pounds, as indicated in 40 C.F.R. Part 355, Appendix A. On July 27, 2023, at or about 4:34 a.m. CDT, a release of…...

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EPA RMP GDC citations @ manufacturing, packaging, and distribution facility (NH3 & $36K w/ a $97K SEP)

Respondent operated a manufacturing, packaging, and distribution facility that is located immediately across the street from a residential neighborhood, less than a half mile from a high school and several businesses, and approximately a mile from US. Routes 5 and 84 and the Connecticut River. At all times relevant to the violations alleged herein, the…...

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EPA RMP GDC citations @ manufacturing, packaging, and distribution facility (NH3 & $36K w/ a $97K SEP) Read More »

EPA RMP citations @ colloidal and polymer blend manufacturing facility (Epichlorohydrin and Dimethylamine & $401K)

The Facility is a colloidal and polymer blend manufacturing facility. The Facility has used Epichlorohydrin and Dimethylamine to manufacture chemicals on site since at least 1999. The Facility maintains a maximum inventory of 235,000 pounds of the regulated toxic substance Epichlorohydrin, as determined under 40 C.F.R. § 68.115, which exceeds the threshold quantity of 20,000…...

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EPA RMP citations @ colloidal and polymer blend manufacturing facility (Epichlorohydrin and Dimethylamine & $401K) Read More »

EPA GMP RMP & EPCRA citations @ cheese production facility (NH3 & $178K)

The respondent was the owner or operator of a cheese production facility that used anhydrous ammonia in its refrigeration processes. Respondent was required to have a material safety data sheet for anhydrous ammonia under the Occupational Safety and Health Act of 1970 and its associated regulations. Respondent produced, processed, handled, or stored a regulated substance…...

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EPA RMP & EPCRA citations @ food facility (NH3 & $210K)

Respondent operated a facility that utilizes anhydrous ammonia to provide cooling capabilities to processing, shipping, cooler areas, silos, and chillers for its beef and meat products. On March 30, 2022, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, EPCRA Sections 304-312,…...

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EPA RMP & EPCRA citations @ ammonium phosphate fertilizers and sulphuric acid manufacturing facility ( NH3, Aqua NH3, H2SO4 7 $363K)

Respondent operated a facility that manufactures ammonium phosphate fertilizers and sulphuric acid. EPA conducted an on-site investigation of Respondent’s operations at the Facility pursuant to CAA Section 112(r), EPCRA Sections 304-12, and CERCLA Section 103 on January 30, 2020 (the “Inspection”). Respondent has informed EPA that the Facility no longer has any ammonia onsite as…...

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