PSM and RMP Citations/Analysis

I came across this EPA Region 6 RMP inspection report while doing some research for a client and this is an amazing insight into the difficulties and details of implementing a Process Safety Management System. I always take out names and company names when I post inspection reports, as it is NEVER about the company,…...

This inspection appears to have begun as an RMP GDC, but when the facility submitted an RMP after the first inspection, they stated the process was a Program 3, and thus it appears EPA paid them another visit.  On both visits, EPA seems to have found items of concern. Respondent is the owner and/or operator of…...

OSHA has cited a refinery for failing to control the use and release of highly hazardous chemicals after an explosion and fire injured several employees. The company faces $83,150 in proposed penalties.  Here is a break down of the citations:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

Respondent operates a facility where it processes fish to produce ingredients used by pet food manufacturers (the “Facility”). The Facility is located in a designated industrial area within approximately 300 feet (0.05 mile) of JFK Memorial Highway, less than 500 feet (0.09 mile) from the nearest residence, and approximately 600 feet (0.11 mile) from Buzzard’s…...

Respondent owned and operated two food warehousing facilities. One is used for food manufacturing and refrigerated warehouse and storage. The other is used for refrigerated storage. On January 26, 20 17, EPA conducted a compliance inspection at the food manufacturing facility, as well as a records review of the risk management plan (submitted to EPA…...

Respondent is the owner and operator of the facility where anhydrous ammonia is a “regulated substance” pursuant to 40 C.F.R. § 68.3. On or about November 15, 2017, EPA conducted an inspection of Respondent’s Facility to determine compliance with 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had greater than…...

Respondent is the owner and/or operator of a meat processing facility that uses, handles, and/or stores more than a threshold quantity of anhydrous ammonia, which is a regulated substance, listed under 40 C.F.R. § 68.130. Respondent meets the Program 3 eligibility requirements under 40 C.F.R. § 68.10. On December 12, 2016, EPA conducted an inspection…...

Respondent is a Plant Food Company and is an owner or operator of vessels containing anhydrous ammonia located at the Facility. The vessels are a “stationary source” pursuant to 40 C.F.R. § 68.3. On or about March 1, 2017, EPA conducted an inspection of the Facility to determine compliance with Section 112(r) of the CAA…...

Respondent owned and operated a primary metal products manufacturing facility that produces annually over 300,000 tons of powdered metal which is used in the production of automotive parts. Hydrogen is handled in the production of powdered metal, and hydrogen is a regulated flammable substance listed under 40 C.F.R. § 68.130. The Facility receives scrap iron…...

Respondent owns and operates the egg production facility which utilizes anhydrous ammonia in a refrigeration process. On or about August 1-2, 2017, EPA conducted an inspection to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68 (EPA inspection). Information gathered during the EPA inspection revealed that Respondent had greater than 10,000…...

NOTE: this case has some very interesting citations and used RAGAGEPs that may not be the best fit, but when a facility does not adopt a RAGAGEP, EPA (and OSHA) will be more than happy to “suggest” one in their citations! Respondent is the owner and/or operator of a natural gas processing facility. The Facility…...

The Facility is a “stationary source” that processed, handled, and stored isopropyl alcohol. Isopropanol (isopropyl alcohol, CAS #67-63-0) is a highly flammable liquid and extremely hazardous substance. On or about April 13, 2017 there was a fire at the Facility resulting in an accidental release.  Between May and July 2017, EPA requested and the business provided…...