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 @ 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 citations @ food ingredients facility (NH3, H2 & $207K w/ $122K 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/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/EPCRA citations @ food facility (NH3 & $25K w/ $90K SEP) Read More »

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 GDC citations @ bulk storage facility (Flammable Liquids & $23K w/ $150K SEP) Read More »

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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EPA RMP and EPCRA citations @ water treatment plant (Cl2 & $47K w/ $250K SEPs)

Respondent owns and operates a wastewater treatment plant that uses chlorine, stored as liquified gas under pressure, to disinfect wastewater. In its October 2020 risk management plan, the plant indicated that it stored up to 12,000 pounds of chlorine on-site in one-ton cylinders. On November 3, 2022, EPA performed an inspection of the plant to…...

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EPA RMP and EPCRA citations @ water treatment plant (Cl2 & $47K w/ $250K SEPs) Read More »

OSHA PSM citations @ Food plant (NH3 & $64K)

The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA RMP GDC & EPCRA citations @ facility that produces glass-to-metal seals and high-temperature co-fired ceramics (NH3 & $117K)

Respondent operates a facility that produces glass-to-metal seals and high-temperature co-fired ceramics for use in semiconductor products. The Facility is located just over half a mile from a residential neighborhood; just under three-quarters of a mile from a charter school; just over three-quarters of a mile from a church and a skating rink; less than…...

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EPA RMP GDC & EPCRA citations @ facility that produces glass-to-metal seals and high-temperature co-fired ceramics (NH3 & $117K) Read More »

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