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 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…...

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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,…...

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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…...

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EPA RMP citations @ chemical manufacturer (Phosgene & $75K)

Respondent has a chemical manufacturing process at the Facility, meeting the definition of “process”, as defined by 40 C.F.R. § 68.3. The Facility experienced an accidental release of phosgene on December 4, 2023. Phosgene is a substance listed pursuant to Section 112(r)(3) of the CAA in 40 C.F.R. § 68.130. From the time Respondent first…...

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EPA RMP Citations @ sulfuric acid manufacturer (NH3, CS2, CH 3SH, C3H6, C2S5SH & $40K)

Respondent has six regulated substances present at the Facility:anhydrous ammonia, carbon disulfide, 2-butene, 3-butadiene, propylene, and ethyl mercaptan. Respondent’s Facility manufactures sulfuric acid and regenerates spent sulfuric acid, meeting the definition of “process”, as defined by 40 C.F.R. § 68.3. Respondent has a quantity of the aforementioned chemicals greater than the threshold. ALLEGED VIOLATIONS TrainingOf…...

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EPA RMP GDC citations @ pool supply business (Ca(ClO)2 & $37K

On September 25, 2024, an incident at the Facility resulted in an accidental release. EPA sent an informal questionnaire to the respondent on April 17, 2025. Respondent provided documentation and information on June 9, 2025. Based on the response provided on June 9, 2025, EPA conducted an investigation of the Facility to determine Respondent’s compliance…...

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EPA RMP citations @ pet food ingredient manufacturing facility after three (3) NH3 releases (NH3 & $176K)

Respondent owns and operates a pet food ingredient manufacturing facility. Respondent reported three accidental releases to the National Response Center prior to EPA’s inspection. On January 9, 2023, Respondent reported a release of 12 pounds of anhydrous ammonia due to a safety release valve failure. On February 23, 2023, Respondent reported a release of 2…...

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EPA RMP citations @ aluminum smelting facility (Cl2 & $75K)

Respondent operated a facility that utilizes chlorine for its aluminum smelting process for use primarily in the automotive and aerospace industries. On June 6, 2023, EPA performed an inspection ofthe Facility to evaluate compliance with the Comprehensive Environmental Response, Compensation and Liability Act Section 103, Emergency Planning and Community Right-to-Know Act EPCRA Sections 304-312, and…...

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EPA RMP Program 2 Citations @ agricultural supply business (NH3 & $24K)

Respondent owns and operates an agricultural supply business. Respondent began operations in or around 1970. On or about February 22, 2023, representatives of the EPA and Nebraska Department of Energy and Environment conducted an inspection of the Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68 (the Inspection)…....

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EPA issues RMP GDC for PRCS Fatality @ Water Treatment Plant

On April 26, 2024, there was an incident at the Facility that resulted in the fatality of one (1) worker while working in a scum pit. EPA sent an informal questionnaire to the Respondent, and the Respondent provided documentation and information concerning the Incident and the Respondent’s compliance with Section 112(r) of the CAA and…...

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EPA RMP Citations @ food plant (NH3 & $37K)

Respondent is the owner and operator of a facility. On September 1, 2024, an incident at the Facility resulted in an accidental release. EPA requested follow-up information, and Respondent provided a response on May 27, 2025, regarding the Incident and Respondent’s compliance with Section 112(r) ofthe CAA and 40 C.F.R. Part 68. Based on the…...

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EPA RMP Citations @ Bakery (NH3 & $133K)

Respondent owns and operates an ammonia refrigeration system at its bakery. The Facility maintains an amount of anhydrous ammonia within its system that is above the 10,000 lbs threshold quantity that is set forth in Table 1 at 40 C.F.R. § 68.130. The Facility is subject to Program 3 because the covered process is subject…...

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