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 @ two agricultural storage facilities (NH3 & $120K)

Respondent is a cooperative with two (2) facilities that store ammonia. On June 26th and September 6, 2012, EPA conducted inspections of the facilities to determine the Respondent’s compliance with the Risk Management Program 2 Prevention Program requirements. The inspections confirmed that the facilities had more than a threshold amount of anhydrous ammonia. Facility #1

EPA RMP Program 2 citations @ agricultural storage and supply facility (NH3 & $35K)

On or about September 18, 2018, EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of anhydrous ammonia in a process at its facility. From the time Respondent first

EPA RMP citations @ chemical manufacturing and distribution facility (Anhydrous and Aqua Ammonia & $79K)

Respondent owns and operates the chemical manufacturing and distribution facility. Anhydrous ammonia is a “regulated substance” pursuant to 40 C.F.R. § 68.3 with a threshold quantity, as listed in 40 C.F.R. § 68.130, of 10,000 pounds. Ammonia in the concentration of greater than 20% is a “regulated substance” pursuant to 40 C.F.R. § 68.3 with

EPA RMP Program 2 citations @ agricultural storage and supply facility (NH3 & $20K w/ $25K SEP)

Respondent owns and operates an agricultural storage and supply facility where on August 16, 2016, an accidental release of anhydrous ammonia occurred when filling a storage tank. The release resulted in the hospitalization of an employee. On or about March 12, 2019, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance

EPA RMP citations @ LPG Railcar filling facility (LPG & $14K)

On July 12, 2017, authorized EPA representatives conducted a compliance inspection of the facility to determine its compliance with the Risk Management Program (“RMP”) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Act. Following the inspection, EPA requested certain documents and information and reviewed the provided information with support from outside

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