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 & $103K)

Respondent is a Gourmet Pasta Company that uses anhydrous ammonia in two refrigeration “processes,” as defined by 40 C.F.R. § 68.3, in two separate systems of pipes and vessels at the Facility (the “Processes”). On October 12, 2016, Respondent conducted a Process Hazard Analysis (“PHA”) for the Facility. On March 30, 2017, Respondent filed an […]

EPA RMP citations @ Anhydrous Ammonia storage and refrigeration process (NH3 & $244K)

Respondent stores and uses ammonia at the facility in parts of the storage and refrigeration process. Respondent’s storage and refrigeration process contains more than the threshold quantity (10,000 pounds) of ammonia. Respondent’s storage and refrigeration process does not meet the eligibility requirements for Program 1 under 40 C.F.R. § 68.10(b) and is subject to the

EPA RMP citations @ food facility (NH3 & $85K – COVID19 penalty reduction)

SPECIAL NOTE:  This is the first time I have seen a penalty reduction from the COVID-19 impacts on the business. Respondent operates an ammonia refrigeration process with 15,416 pounds of anhydrous ammonia. The Respondent has one RMProgram level 3 covered process, which stores or otherwise uses a toxic substance in an amount exceeding its applicable

EPA RMP citations @ poultry processing facility (NH3 & $104K)

Respondent operates an ammonia refrigeration system which uses 30,345 pounds anhydrous ammonia (ammonia). Respondent has one RMProgram level 3 covered process, which stores or otherwise uses an extremely hazardous substance in an amount exceeding its applicable threshold of 10,000 pounds. On December 21, 2017, the EPA conducted an onsite inspection of the RMProgram related records

EPA RMP citations @ agricultural chemical manufacturing facility (Cl2 release w/ 2 injuries & $31K)

Respondent owns and operates an agricultural chemical manufacturing facility. On November 2, 2017, Respondent had an accidental release of chlorine at the Facility. Respondent determined the amount of chlorine released to be 0.014 pounds and reported that the release occurred when hooking up a rail car containing chlorine in which an unloading valve was inadvertently

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