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 transfer and storage facility (NH3 & $52K)

Respondent is the owner of a food transfer and storage facility and according to their risk management plan for the Facility, Respondent uses approximately 25,225 pounds of anhydrous ammonia in its closed-loop industrial ammonia refrigeration system.  On October 2, 2018, EPA conducted an inspection of the Facility to determine whether Respondent was in compliance with

EPA RMP citations @ refinery (Butane and HF)

On November 1 through November 4, 2016, representatives from the U.S. Environmental Protection Agency (“EPA”) Region IX conducted an inspection of the XXXXXXXX refinery. EPA’s inspection was conducted to determine compliance with the Risk Management Program (“RMP”) promulgated under Section 112(r)(7) of the Clean Air Act (“CAA”‘), and the General Duty Clause under Section 112(r)(l)

EPA RMP GDC @ refrigerated food distribution warehouse (NH3 & $101K)

At all relevant times, Respondent owned and operated a refrigerated food distribution warehouse with an ammonia refrigerant system which contains approximately 9,617 pounds of ammonia. EPA inspected the facility on August 9, 2018. Prior to the August 9, 2018, inspection, Respondent had not performed a hazard analysis nor developed standard operating procedures for the ammonia

EPA RMP Program 2 citations @ agriculture retail facility (NH3 & $20K, w/ $80K SEP)

On or about August 10, 2018, representatives of the 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 the capacity to store 650,000 pounds of anhydrous ammonia at the Facility, and regularly stored

EPA RMP citations @ gluten, starch, and alcohol production facility AFTER a WRONG CHEMICAL – WRONG TANK incident caused a Cl2 release (Propylene oxide & $250K)

Lesson’s learned:  A WRONG CHEMICAL – WRONG TANK incident produced a chlorine release and brought EPA to the facility.  The EPA inspection does not appear to have looked at the Cl2 incident, but rather stayed focused on the propylene oxide process – their “covered process”.  As well, in March of this year both the facility

EPA RMP citations @ gluten, starch, and alcohol production facility AFTER a WRONG CHEMICAL – WRONG TANK incident caused a Cl2 release (Propylene oxide & $250K)

Lesson’s learned:  A WRONG CHEMICAL – WRONG TANK incident produced a chlorine release and brought EPA to the facility.  The EPA inspection does not appear to have looked at the Cl2 incident, but rather stayed focused on the propylene oxide process – their “covered process”.  As well, in March of this year both the facility

EPA RMP Program 2 citations @ agriculture retail facility (NH3 & $45K, w/ $8K SEP))

Respondent operated an agriculture retail facility and receives, stores, and sells anhydrous ammonia. On or about June 19, 2018, representatives of the 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 the facility had ammonia

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