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 General Duty citations @ Pet Food facility (NH3 & $89K w/ SEP $99K)

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

EPA RMP citations @ meat processing facility (NH3 & $72K, w/ $113K SEP)

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

EPA RMP GDC citations @ metal products manufacturing facility (H2 & $160K)

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

EPA RMP GDC citations @ chemical facility (Isopropanol fire & $24K, w/ $100K SEP)

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

EPA RMP citations @ food storage and distribution facility (NH3 & $14K)

Respondent is the owner and operator of a Facility that utilizes approximately 32,000 pounds of anhydrous ammonia in its refrigeration system at the Facility. Respondent uses anhydrous ammonia in a series of interconnected pipes and vessels in a refrigeration system at the Facility (the “Process”). On June 26, 2017, EPA conducted an inspection of the

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