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 @ food facility (NH3 & $33K)

Respondent is the owner and/or operator of the Facility, which is a “stationary source” and has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility:(a) Respondent operates an ammonia refrigeration plant.(b) At all times relevant to the violations alleged, Respondent…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

EPA RMP citations @ food facility (NH3 & $160K)

At all times relevant to this CAFO, Respondent operated a facility that utilizes anhydrous ammonia to produce approximately one-quarter billion frozen burritos for distribution nationwide each year. On July 20, 2022, EPA performed an inspection of the Facility to evaluate compliance with the CERCLA Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

EPA RMP/EPCRA citations @ Refinery (HF & $270K)

Respondent operated a facility (the “Facility”) that refines petroleum products using a hydrofluoric acid alkylation process. On June 2-3, 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, and CAA Section 112(r). Based upon the information gathered during…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

EPA RMP/EPCRA citations @ ethanol manufacturing facility (Flammables & $169K)

Respondent is the owner and operator of an ethanol manufacturing facility handling a mixture of hydrocarbon liquids, butane, isopentane, and pentane. Pursuant to 40 C.F.R. § 68.115(b)(2)(i), the entire weight of the mixture shall be treated as the regulated substance when the concentration of each of the regulated substances is 1% or greater by weight…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

EPA RMP/EPCRA citations @ food facility (NH3 & $262K)

Respondent operated a facility that utilizes anhydrous ammonia to provide cooling capabilities to package, refrigerate, store, and ship cherries and grapes.On September 16, 2021, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon the…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

EPA RMP & EPCRA citations @ formaldehyde facility (HCHO & $382K)

The Facility includes storage tanks, pumps, and transfer piping, and other buildings, structures, equipment, installations, or substance-emitting stationary activities from which an accidental release of a regulated substance may occur; which belong to the same industrial group; which are located on one or more contiguous properties; and which are under the control of the same…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

EPA RMP citations @ pork manufacturing facility (NH3 & $90K)

Respondent is the owner and operator of a pork manufacturing and supply business. As reported in the Respondent’s risk management plan, anhydrous ammonia, Chemical Abstract Service (“CAS”) Number 7664-41-7, is used at the Facility to cool and freeze its pork products. The Facility’s freezing and cooling system holds 201,852 pounds of anhydrous ammonia. On August…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

EPA RMP citations @ food facility (NH3 & $186K)

Respondent owns a facility (the “Facility”) that uses anhydrous ammonia as a refrigerant for produce processing and packaging. On July 9, 2024, 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, and CAA Section 112(r). Based upon the information…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

EPA RMP Program 2 citations @ fertilizer distribution business (NH3 & $119K)

Respondent owns and operates two (2) anhydrous ammonia distributing facilities. EPA Region 7 conducted inspections at the one (1) facility in August 2023 and at the other facility in December 2024 to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspections revealed that Respondent hadcgreater…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

EPA RMP Citations @ food facility (NH3 & $164K)

The company owns and operates an ammonia refrigeration system at its production facility, specializing in egg products and breakfast-style entrees. The Facility uses a two-stage, closed-loop, ammonia refrigeration system to refrigerate the food items. The ammonia refrigeration system at the Facility includes eleven compressors, fifteen evaporators, ten make-up air units, seven condensers, three heat exchangers,…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here

EPA RMP citations @ ferric chloride manufacturing facility (Cl2 & $20K)

The Respondent owns and operates a ferric chloride manufacturing facility, which maintains a maximum inventory of 3,000,000 pounds of the regulated toxic substance chlorine, as stated in the December 21, 2021, RMP that was submitted to and reviewed by EPA. Chlorine is a regulated toxic substance under Section 112 of the CAA with a threshold…...

Membership Required

You must be a member to access this content.

View Membership Levels

Already a member? Log in here
Scroll to Top