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 & $93K)

Respondent owns and operates a processed cheese manufacturing facility. On or about December 16-18, 2024, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance with 40 C.F.R. Part 68 (the “Subject Compliance Inspection”). Information gathered during the EPA’s Inspection revealed that the Respondent had greater than 10,000 pounds of anhydrous ammonia…...

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EPA RMP Citations @ food facility (NH3 & $130K)

At all times relevant to this CA/FO, Respondent operated a facility (the “Facility”) that utilizes anhydrous ammonia for cooling to pack, process, and distribute its food products. On July 11, 2024, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) Section 103, the Emergency…...

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EPA RMP Citations @ food facility (NH3 & $106K)

At all times relevant to this CA/FO, Respondent operated a facility (the “Facility”) that utilizes anhydrous ammonia to manufacture and produce citrus products, to develop frozen fruit concentrate, juice, oils, and pulps from oranges, lemons, and grapefruits. On October 24, 2023, EPA performed an inspection of the Facility to evaluate compliance with the Comprehensive Environmental…...

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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…...

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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…...

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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…...

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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…...

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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…...

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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…...

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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…...

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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…...

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