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 @ ammonia cold storage facility (NH3 & $43K)

Respondent operates a cold food storage facility and has on-site for use, 14,000 pounds of anhydrous ammonia for cold food storage purposes. The respondent’s process is an RMProgram level 3 covered process. On March 29, 2017, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the…...

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EPA RMP citations @ ammonia refrigerant facility (NH3 & $33K)

Respondent operates an ammonia refrigerant facility with 19,000 pounds of ammonia for food refrigeration purposes. The process is an RMProgram level 3 covered process. On March 24, 2016, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the…...

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EPA RMP citations (Flammables)

On or about August 22-23, 2017, EPA conducted an inspection (the inspection) of the Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information collected as a result of the inspection revealed that Respondent failed to implement the risk management program at the Facility.  The following substances are a…...

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EPA RMP citations @ pork harvesting, processing, and packaging facility (NH3 & $58K)

Respondent is the owner and operator of a pork harvesting, processing, and packaging facility which utilizes 250,000 pounds of anhydrous ammonia in its refrigeration system.  On April 20, 2016, EPA inspected the Facility in order to determine the Facility’s compliance with the Chemical Accident Prevention Provisions of 40 C.F.R. Part 68.  Based upon the information…...

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EPA RMP citations @ Cold Storage Facility (NH3 & $107K)

SAFTENG NOTE:  This is the first time I have come across a citation from either OSHA or EPA where they took issue with the Ammonia Flammability Limits as depicted on the NFPA 704 Diamond located on the engine/machinery room door.  The facility had not updated their label to show NH3 as an F=3 for indoors;…...

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EPA RMP citations @ WWTP (Cl2 & $10K w/ $64K SEPs)

Respondent is a municipality in the state of Nebraska, which owns and operates a Water Treatment Plant.   Information gathered during the EPA inspection revealed that Respondent had greater than 2,500 pounds of chlorine in a process at its facility.  From the time Respondent first had on site greater than 2,500 pounds of chlorine in a…...

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EPA RMP citations @ dairy (NH3 & $86)

Respondent operates a dairy plant and has on-site, 13,000 pounds of anhydrous ammonia which is used in its ammonia refrigeration process.  Respondent submitted a single RMPlan that included an accidental release prevention program, to the EPA for its stationary source.  At its stationary source, the Respondent has one RMProgram level 3 covered process.  On January…...

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EPA RMP Program 2 citations @ fertilizer facility (NH3 & $51K)

Respondent operates ammonia storage and transfer process which contains 840,000 pounds of anhydrous ammonia for storage and transfer. Respondent has one RMProgram level 2 covered process.  On March 3, 2016, the EPA conducted an onsite inspection of the RMProgram related records and equipment to assess the Respondent’s compliance with the RMProgram requirements and the implemented…...

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OSHA PSM citations @ polysilicon facility (H2 Compressor Explosion & $25K)

A hydrogen compressor explosion led to some injuries and a TOSHA inspection, resulting in some PSM citations…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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EPA RMP & GDC citations @ chemical manufacturing facility (Cl2 & H2 & Action Plan)

Respondent has owned and operated a chemical manufacturing facility since at least January 2013. The facility manufactures chlorine, sodium hydroxide, solid sodium hydroxide, hydrochloric acid and calcium hypochlorite. The Facility is primarily a manufacturer of chlorine, which is produced through the electrolysis of a sodium chloride being derived from a salt vein deep under the…...

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EPA RMP & EPCRA citations @ cold storage facilities (NH3 & $329K for RMP and $90K for EPCRA)

Respondent is the owner and/or operator of five (5) cold storage facilities. Two of the facilities are both in the same industrial group, are located across a road from each other and are therefore located on one or more contiguous properties. Both are under the control of Respondent and are buildings that contain equipment that…...

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EPA RMP & EPCRA citations @ cold storage facilities (NH3 & $329K for RMP and $90K for EPCRA) Read More »

EPA RMP citations @ agricultural chemical manufacturing facility (CH4S, C3H9N, C2H7N, NH3 & $72K )

Respondent owns and operates an agricultural chemical manufacturing facility. On or about August 18-19, 2015, 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 methyl mercaptan in a…...

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