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 @ fertilizer manufacturing facility (GMAP, DAP, and NH3 & $217K w/ $100K SEP)

Respondent operates a granular monoammonium phosphate (GMAP) process and a diammonium phosphate (DAP) process at the Facility, meeting the definition of “process”, as defined by 40 C.F.R. § 68.3. A different Respondent operates an anhydrous ammonia process at the Facility, meeting the definition of “process”, as defined by 40. C.F.R. § 68.3. The GMAP and…...

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EPA RMP citations @ fertilizer manufacturing facility (GMAP, DAP, and NH3 & $217K w/ $100K SEP) Read More »

EPA RMP citations @ specialty chemicals facility (Flammables and Toxics & $1.4M)

Respondent is the owner and operator of the facility. On October 15, 2022, there was an incident at the Facility that resulted in an accidental release of approximately 17,598 pounds of Aluminum Triethyl (ATE). The Incident resulted in an on-site chemical fire at the Facility and a shelter-in-place for the surrounding community. The Respondent’s facility…...

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EPA RMP citations @ specialty chemicals facility (Flammables and Toxics & $1.4M) Read More »

EPA RMP citations @ refrigerated distribution center and warehouse (NH3 & $161K)

The Respondent formerly operated an ammonia refrigeration process at a distribution center and warehouse, which maintained a maximum inventory of the regulated toxic substance anhydrous ammonia at the Facility, which exceeds the threshold quantity of 10,000 pounds of anhydrous ammonia as set forth in Table 1 at 40 C.F.R. § 68.130 and, therefore, has had…...

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EPA RMP citations @ refrigerated distribution center and warehouse (NH3 & $161K) Read More »

EPA RMP citations @ cheese manufacturing facility (NH3 & $229K w/ $179K SEP)

Respondent owns and operates a cheese manufacturing facility. On March 22, 2022, EPA inspected the Facility to evaluate compliance with CERCLA Section 103, EPCRA Sections 304-312, and the GDC of CAA Section 112(r). Based upon the information gathered during the Inspection and subsequent investigation, EPA determined that Respondent violated certain provisions of CERCLA, EPCRA, and…...

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EPA RMP citations @ cheese manufacturing facility (NH3 & $229K w/ $179K SEP) Read More »

EPA RMP citations @ ice cream plant (NH3 & $176K w/ $85K SEP)

Respondent owns and operates an ammonia refrigeration system at its ice cream novelty manufacturing facility, which maintained a maximum inventory of the regulated toxic substance anhydrous ammonia at the Facility, exceeding the threshold quantity of 10,000 pounds of anhydrous ammonia. The ammonia refrigeration system at the Facility services 3 freezer rooms and consists of 12…...

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EPA RMP citations @ ice cream plant (NH3 & $176K w/ $85K SEP) Read More »

EPA issues RMP citations @ cheese manufacturing plant (NH3, Line Break Accident, & $38K)

This is an unusual case in that it involved a 20-pound release of NH3 during a “line break” on a refrigeration system.  There was only a single citation and it came at a price of $38,500.  The employee was injured.  I have been unable to locate an OSHA investigation regarding this incident, which occurred in…...

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EPA issues RMP citations @ cheese manufacturing plant (NH3, Line Break Accident, & $38K) Read More »

EPA issues RMP citations @ commercial explosives plant (NH3 & Cl2 & $394K)

The Facility uses, handles, and/or stores more than a threshold quantity of ammonia (anhydrous), ammonia (concentration 20% or greater), and chlorine, which are regulated substances, as specified at 40 C.F.R. §§ 68.115 and 68.130. The Facility’s Cooling Tower 2 chlorine injection area contains up to 4,000 lbs of chlorine in two (2) 1-ton cylinders, above…...

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EPA issues RMP citations @ commercial explosives plant (NH3 & Cl2 & $394K) Read More »

EPA issues RMP citations @ chemical transfer business (Flammables and Toxics & $10K w/ a SEP of $41K)

Respondent has a P-Tank Farm Vinyl Acetate Monomer {VAM), D-Tank Farm Toluene Diisocyanate (TDI), and the Isopentane and Isopentane/n-Pentane blend Intermodal Transfer processes at the Facility, meeting the definition of “process,” as defined by 40 C.F.R. § 68.3. Isopentane, pentane, acrylonitrile, toluene diisocyanate (unspecified isomer), and vinyl acetate monomer are each a “regulated substance” of…...

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EPA issues RMP citations @ chemical transfer business (Flammables and Toxics & $10K w/ a SEP of $41K) Read More »

EPA issues RMP & EPCRA citations @ food facility (NH3 & $229K w/ $179K SEP)

Respondent owns and operates a cheese manufacturing facility. On March 22, 2022, EPA performed an inspection of the Facility to evaluate compliance with CERCLA Section 103, EPCRA Sections 304-312, and CAA Section 112(r). Based upon the information gathered during the Inspection and subsequent investigation, EPA determined that Respondent violated certain provisions of CERCLA, EPCRA, and…...

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EPA issues RMP & EPCRA citations @ food facility (NH3 & $229K w/ $179K SEP) Read More »

OSHA issues PSM citations @ paint manufacturing plant (Flammable/Reactives & $290K)

OSHA issued $290,358 in proposed penalties following an August 2023 explosion at a paint factory in Garland, TX. One employee was injured in the explosion at the factory. OSHA issued one repeat and eight serious citations. The repeat citation was a $161,310 proposed penalty. The proposed penalties for the eight other citations are $16,131 each…....

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OSHA issues PSM citations @ paint manufacturing plant (Flammable/Reactives & $290K) Read More »

EPA issues RMP citations @ automobile manufacturer heart treating process (NH3 & $12K w/ 3 SEPs of $59K)

Respondent owns and operates a metal parts heat treatment operation and maintains a maximum inventory of 60,000 pounds of anhydrous ammonia, at the Facility, which exceeds the threshold quantity of 10,000 pounds. Respondent uses anhydrous ammonia in its heat treatment process. EPA inspectors completed an announced CAA 112(r) inspection on June 15 through June 16,…...

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EPA issues RMP citations @ automobile manufacturer heart treating process (NH3 & $12K w/ 3 SEPs of $59K) Read More »

EPA issues RMP GDC citations @ chemical bulk storage facility (HNO3, H2O2, NaClO, H2SO4 & $74K)

Respondent is supplied with raw chemical feedstocks by tanker truck or railcar. Chemical unloading operations occur on the eastern portion of the Facility at dedicated tank truck and railcar unloading stations. Several chemicals are stored in bulk at the Facility in dedicated aboveground storage tanks (ASTs), including, nitric acid (one tank), hydrogen peroxide (four tanks),…...

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EPA issues RMP GDC citations @ chemical bulk storage facility (HNO3, H2O2, NaClO, H2SO4 & $74K) Read More »

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