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 issues RMP citations @ cold storage (NH3 & $115K)

Respondent owns and/or operates a refrigeration-based cold storage facility which is located within a populated residential, commercial, and industrial area and is adjacent to a significant roadway. At the Facility, Respondent handles, stores, and uses, and has handled, stored, and used anhydrous ammonia.  On April 24, 2018, EPA performed an inspection of the Facility pursuant…...

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EPA issues RMP citations @ CO2 liquification plant (NH3 & $127K)

Respondent owns and operates a carbon dioxide liquification plant, which uses anhydrous ammonia to produce and refrigerate liquid carbon dioxide. On September 19, 2017, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Section 103 of CERCLA, and Sections 302-312 of EPCRA. Based upon the information gathered during this inspection…...

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EPA issues RMP citations @ Ice Cream manufacturer (NH3 & $301K)

Respondent operates a facility to manufacture, store and distribute ice cream and other food products. 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). Respondent was subject to Program 3 requirements because it was subject to the OSHA process safety…...

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EPA issues RMP GDC citations @ chemical wholesale distributor (Flammable Liquids & $0)

Respondent is the owner and operator of a chemical wholesale distributor that repackages and custom-blends chemicals. Respondent formulates two mixes, paper adhesives and lacquer thinners, for sale. Respondent currently operates lacquer thinner mixing and flammable liquid storage systems at the Facility. With regard to the lacquer thinner mixing and flammable liquid storage systems, Respondent produces,…...

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EPA issues RMP GDC citations @ Ice Company (NH3 & $82K)

Respondent owns and operates a facility that produces approximately 300 tons of crushed, cubed, and block ice per day for retail, the fishing industry, and special events. The ice is produced using an anhydrous ammonia refrigeration system.  On April 24, 2017, there was a release of anhydrous ammonia from the 6,500-pound ammonia refrigeration system at…...

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OSHA issues PSM citations @ Ice Cream producer and it’s contractor (NH3 & $200K)

A contractor lost consciousness from ammonia exposure at an ice cream plant leading OSHA to propose more than $200,000 in fines against the company and the contractor.Here is a breakdown of the citations to the facility and the contractor…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log...

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EPA issues RMP citations @ refinery (Flammables & $93K)

Respondent is the owner and/or operator of a Refinery with the NAICS code of 32411, Petroleum Refineries. The Facility refines low sulfur yellow crude into ultra-low sulfur diesel fuel, naptha, heavy gas oil, and vacuum tower bottoms and those processes contain flammable mixtures of regulated substances listed in Table 3 of 40 C.F .R. §…...

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EPA issues RMP citations @ water treatment services provider (Cl2/SO2 & $5K)

NOTE: I normally do not post such small cases; however, this one involved the use of The Chlorine Institute pamphlets as the referenced RAGAGEP and because it is so rare we see Cl2 PSM/RMP citations I wanted to add it to the database. Based on a compliance monitoring inspection conducted at the Respondent’s facility on…...

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EPA issues RMP citations @ aircraft parts and auxiliary equipment manufacturing plant (LPG & $66K)

Respondent is the owner and/or operator of the Facility, which operates an aircraft parts and auxiliary equipment manufacturing plant.  Respondent 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:… Membership Required You must be a member to access this...

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EPA issues RMP citations @ ready-to-eat facility (NH3 & $66K)

Respondent is the owner and/or operator of the facility, which produces fully cooked and ready-to-eat sauces and refrigerated entrees. On December 26, 2018, the EPA issued to Respondent a Notice of Potential Violation (“NOPV”), providing notice that the EPA found that Respondent potentially committed the alleged violations described in Section V of this Agreement and…...

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EPA issues RMP citations @ cold storage (NH3 & $31K)

Respondent operates an ammonia refrigeration plant with 50,629 pounds of anhydrous ammonia which is an RMProgram level 3 covered process. On March 27, 2019, the EPA conducted an on-site inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the implemented recognized and generally…...

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EPA issues RMP citations @ power plant (NH3 & $199K)

On January 17, 2020, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Sections 304-312 of EPCRA, and Section 103 of the Comprehensive Environmental Response, Compensation, and Liability Act. Based upon the information gathered during this inspection and subsequent investigation, EPA asserts that Respondent violated certain provisions of the CAA…...

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